What are Conflict Minerals and the Role of CMRT?

Have you ever thought about where the materials in your smartphone, laptop, or car come from? Many of these products rely on minerals that may be sourced from regions affected by conflict, where unethical mining practices can lead to human rights abuses, environmental destruction, and the funding of armed groups.

To address these concerns, regulatory bodies worldwide have implemented strict compliance rules.

What Are Conflict Minerals?

Conflict minerals are natural resources extracted from areas impacted by armed conflict and human rights violations. The most commonly regulated conflict minerals are tantalum, tin, tungsten, and gold (known as 3TG), which are essential in industries like electronics, automotive, and aerospace.

Why Are Conflict Minerals a Concern?

• Financing Armed Groups: Proceeds from mineral sales may fund violence and conflict.
• Human Rights Violations: Many miners, including children, face dangerous conditions and forced labor.
• Environmental Impact: Mining activities can lead to deforestation, water contamination, and habitat loss.

To ensure that supply chains are ethical and sustainable, companies must take proactive measures to source responsibly.

Conflict Minerals in the Supply Chain

The 3TG supply chain is complex, often involving multiple intermediaries before reaching manufacturers. Minerals are:

1. Mined—Often by small-scale or informal operators.
2. Sold to Traders—Who mix them with minerals from other regions, making tracing difficult.
3. Processed by Smelters—Refined into metals for industrial use.
4. Used by Manufacturers—To create components for various consumer products.

Since minerals change hands many times, companies must implement rigorous due diligence to ensure they source responsibly.

U.S. Dodd-Frank Act Section 1502

The Dodd-Frank Wall Street Reform and Consumer Protection Act, enacted in 2010, includes Section 1502, requiring certain companies to disclose their use of conflict minerals.

Key Compliance Requirements under U.S. Dodd-Frank Act Section 1502:

✔ Reasonable Country of Origin Inquiry (RCOI): Companies must determine if their 3TG minerals come from the Democratic Republic of the Congo (DRC) or neighboring countries (Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia).

✔ SEC Form SD Filing: If 3TG minerals are essential to a product, companies must disclose their sourcing practices.

✔ Conflict Minerals Report (CMR): If minerals are sourced from affected regions, further due diligence and public disclosure are required.

EU Conflict Minerals Regulation

The EU Conflict Minerals Regulation, effective January 2021, applies to EU-based importers of 3TG minerals, aiming to improve transparency in supply chains.

Key Compliance Requirements under EU Conflict Minerals Regulation:

✔ Tracing minerals back to the smelter or mine of origin.

✔ Following the OECD Due Diligence Guidance for responsible sourcing.

✔ Sharing due diligence findings with downstream purchasers.

✔ Publishing an annual report outlining sourcing efforts.

Unlike the Dodd-Frank Act, which focuses on publicly traded companies, the EU regulation applies to importers regardless of company type.

The Role of CMRT in Conflict Minerals Compliance

The Conflict Minerals Reporting Template (CMRT) is a standardized tool developed by the Responsible Minerals Initiative (RMI) to help companies track the origin of 3TG minerals in their supply chains.

How CMRT Helps Businesses:

✔ Simplifies Supply Chain Data Collection—Standardizes reporting from suppliers. ✔ Identifies Smelters & Refiners—Aids in tracing mineral sources. ✔ Ensures Compliance—Meets regulatory disclosure requirements.

Download our The Complete Guide to Conflict Minerals Reporting to better understand reporting processes, or consult with our compliance experts to streamline your reporting efforts.

Best Practices for Conflict Minerals Compliance

To ensure ethical sourcing and regulatory compliance, businesses should consider the following best practices:

✅ Audit Your Supply Chain—Identify potential conflict minerals use.

✅ Engage with Suppliers—Use CMRT to assess supplier sourcing.

✅ Develop Ethical Sourcing Policies—Work with suppliers to implement responsible practices.

✅ Leverage Third-Party Audits—Verify sourcing integrity through independent assessments.

✅ Educate Teams & Suppliers—Ensure everyone understands compliance requirements.

How Acquis Compliance Can Help

Managing conflict minerals compliance can be complex and time-consuming. Acquis Compliance provides an automated solution that simplifies reporting and reduces risk.

Why Companies Trust Acquis Compliance:

✔ Automated CMRT Collection & Supplier Engagement—Minimizes response fatigue.

✔ Data Validation & Risk Assessment—Ensures accuracy and completeness.

✔ Comprehensive Compliance Reports—Facilitates regulatory submissions.

✔ Support for Both Regulated & Unregulated Minerals—Including EMRTs and Pilot Reporting Templates (PRTs).

Take the stress out of compliance! Request a Free Demo and see how our solutions can simplify your reporting needs.

Final Thoughts

The role of conflict minerals in global supply chains is a critical issue for businesses aiming to uphold ethical sourcing standards. Compliance with Dodd-Frank Section 1502 and the EU Conflict Minerals Regulation is not just a legal requirement—it’s a commitment to responsible business practices.

By adopting best practices, leveraging CMRT for transparency, and utilizing Acquis Compliance’s automated solution, companies can enhance their due diligence processes and ensure a sustainable, conflict-free supply chain.

Are you looking for a simpler way to meet compliance? Schedule a Demo Today!