Completing a CMRT Form
Welcome to the Assent Compliance Conflict Minerals Reporting Template (CMRT) guide. This guide provides comprehensive and direct instructions on filling out a CMRT 6.1 form.
The CMRT is broken down into five sections:
- Company Information.
- Sourcing Questions.
- Policy Questions.
- Smelter Details.
- Product Details.
Each section covers different conflict minerals regulation requirements. The guide covers each section step-by-step and helps identify appropriate answers for different scenarios.
The Company Information section allows manufacturers to declare who they are and which parts they are declaring for. Fields highlighted in yellow are required.
- Company Name: Here manufacturers can list their company name. It is recommended that companies doing business under another name list both company names (e.g. ACME Inc. DBA Fragile Packaging).
- Declaration of Scope or Class: When declaring the source of origin for tin, tantalum, tungsten and gold (3TGs), manufacturers can select the scope of the products to be included in a specific CMRT:
- Company: All products produced by the manufacturer are covered under the CMRT.
- User Defined [‘Specify in Description of scope’]: This allows users to input scope of the parts or products to be included in a specific CMRT. This is usually done at a division level or under a specific category of product. Users that select this type of scope are required to fill the description of the scope on the following row.
- Product (or List of Products): Users can choose to make a list of products that fall under a specific CMRT. The list of products should be filled out under the Product List Tab. Please note: listed products must include a clear description of the product along with a part number.
- Company Unique ID (Optional): List a specific code or number associated with their companies for identification purposes.
- Company Unique ID Authority (Optional): List the authority associated with the ID. This is highly recommended for companies that list a Company Unique ID.
- Address (Optional): List mailing address of the company. This is helpful when declaring under a certain division or business unit, rather than a whole company.
- Contact Name: The individual responsible for dealing with inquiries on the CMRT.
- Email – Contact: The email of the contact listed above.
- Phone – Contact: The phone number for the contact listed above.
- Authorizer: The individual that is responsible for approving the use of the CMRT within a specific company. Please note: In many cases, the Authorizer and the Contact can be the same person.
- Title – Authorizer (Optional): Official title of the Authorizer.
- Email – Authorizer: The email of the Authorizer listed above.
- Phone – Authorizer: The telephone contact for the Authorizer listed above.
- Effective Date: Because sourcing information tends to be collected in waves, it is highly recommended that you keep your company’s CMRT up to date. The effective date allows you to associate a calendar date with the CMRT information. Please note that this date does need to be listed in the Day-Month-Year format to be accepted.
The Sourcing Information section allows manufacturers to enter the information on conflict minerals in their production.
1. Is any 3TG intentionally added or used in the product(s) or in the production process?
- Yes: If the company can confirm the metal in question is intentionally added or used in the product(s) or in the production process.
- No: If the company can confirm the metal in question is not intentionally added or used in the product(s) or the production process.
2. Does any 3TG remain in the product(s)?
- Yes: Company confirms the metal remains in the product(s) after the manufacturing process.
- No: Company confirms the metal does not remain in the product(s) after the manufacturing process.
3. Do any of the smelters in your supply chain source the 3TG from the covered countries?
The covered countries are: Democratic Republic of Congo (DRC), The Republic of Congo, Central African Republic, Tanzania, South Sudan, Burundi, Zambia, Rwanda, Angola and Uganda.
- Yes: Company has found that one or more smelters in its supply chain source the metal in question.
- No: Company has found the metal in question is not sourced from the covered countries. This should only be selected if companies have completely surveyed their supply chain for the covered metal (see Question 5).
- Unknown: Company should select this option if they are still in the process of surveying their supply chains and have not determined if any supplier sources from the covered countries.
4. Do any of the smelters in your supply chain source the 3TG from conflict-affected and high-risk areas?
This question asks if any portion of the 3TGs contained in a product or multiple products originates from conflict-affected and high-risk areas (CAHRAs).
- Yes: Company has found that one or more smelters in its supply chain source the 3TG from conflict-affected and high-risk areas, even if those smelters are on the RMI conformant smelter and refiner list.
- No: Company has found the metal in question is not sourced from conflict-affected and high risk areas. This should only be selected if companies have completely surveyed their supply chain for the covered metal (see Question 5).
- Unknown: Company should select this option if they are still in the process of surveying their supply chains and have not determined if any supplier sources from conflict-affected and high-risk areas.
5. Does 100 percent of the 3TG (necessary to the functionality or production of your products) originate from recycled or scrap sources?
This question asks if the complete sourcing for all conflict metals necessary to the functionality of that product(s) originates from recycled or scrap sources. Please note that if you source from a recycler or scrap smelter you still must list the smelter on the Smelters Details page.
- Yes: Company has confirmed the entire (100%) sourcing for the affected metal is from a recycle or scrap smelter.
- No: Company has confirmed it has found at least one source that is not a recycle or scrap supplier for the affected metal.
- Unknown: Company has yet to complete surveying suppliers and has yet to find a source that is not a recycle or scrap supplier.
6. What percentage of relevant suppliers have provided a response to your supply chain survey?
This question asks how much of your supply chain for the declared products have responded to your inquiries on sourcing and provided information. Answers are broken down into intervals for each affected metal. Companies have the option to list exact percentages in the comments section.
- 100% of the supply chain has responded.
- Greater than 90% of the supply chain has responded.
- Greater than 75% of the supply chain has responded.
- Greater than 50% of the supply chain has responded.
- 50% or less of the supply chain has responded.
- None of the supply chain has responded.
7. Have you identified all of the smelters supplying the 3TG to your supply chain?
This question asks if the manufacturer has been able to identify all the smelters listed from the parts covered within the CMRT.
- Yes: All smelters have been identified for the covered parts.
- No: Not all smelters have been identified for the covered parts.
8. Has all applicable smelter information received by your company been reported in this declaration?
Since smelter data may not always be accurate, it is important to list reasons of why all smelter data may not be listed on the CMRT (e.g. confirming smelter identity).
- Yes: All smelter data has been listed on the smelter list tab.
- No: Not all smelter data has been listed on the smelter list tab.
The Policy Questions section allows manufacturers to state their company policy and position on conflict mineral sourcing.
A. Have you established a conflict minerals sourcing policy?
- Yes: Our company has a policy in place.
- No: Our company does not have a policy in place.
B. Is your conflict minerals sourcing policy publicly available on your website?
- Yes: Company policy is available on our company website (user must list the URL of policy in the comments section).
- No: Company policy is not listed on our company website.
C. Do you require your direct suppliers to source the 3TG from smelters whose due diligence practices have been validated by an independent third party audit program?
- Yes: We require all smelters of our suppliers to go through an independent third party audit to confirm they are sourcing conflict-free 3TGs.
- No: We do not require smelters that source to our suppliers to go through an independent third party audit.
D. Have you implemented due diligence measures for conflict-free sourcing?
- Yes: We have investigated the information provided to us by our suppliers to determine conflict-free status of our 3TGs.
- No: We have not investigated the information provided by our suppliers for 3TG sourcing to determine conflict-free status.
E. Does your company conduct conflict minerals survey(s) of your relevant supplier(s)?
- Yes: Our company conducts conflict minerals survey(s) of our relevant suppliers by collecting information as an IPC-1755 or a CMRT.
- No: Our company does not conflict minerals survey(s) of our relevant suppliers.
F. Do you review due diligence information received from your suppliers against your company’s expectations?
- Yes: We run verification on due diligence findings against our company policy to see if the verification done by our suppliers aligns with our own.
- No: We do not run verification of due diligence findings from our suppliers against our company policy.
G. Does your review process include corrective action management?
- Yes: We do obligate suppliers to implement a conflict minerals process if we deem their efforts are not sufficient.
- No: We do not obligate suppliers to implement a conflict minerals process if we deem their efforts are not sufficient.
H. Is your company required to file an annual conflict minerals disclosure with the SEC?
- Yes: We are a publicly-traded company and are required to file with the SEC our conflict minerals findings every year.
- No: We are not a publicly-traded company are not required to file with the SEC.
SMELTER INFORMATION (SMELTER LIST TAB)
The Smelter List tab allows companies to list all the smelters they have been able to find in their supply chains. Companies can select 3TGs from the first column and then select from one of the authorized smelters listed within the actual CMRT. These are smelters that have approached the RMI to begin the process of verifying themselves as being conflict-free.
PLEASE NOTE: Smelters listed on the CMRT are not necessarily conflict-free. All this means is that the smelter has begun the process to verifying themselves as conflict-free. An updated list of RMAP Conformant Smelters & Refiners can be found on the RMI website at the link below: http://www.responsiblemineralsinitiative.org/conformant-smelter-refiner-lists/
It is possible to list a smelter that is not displayed on the CMRT by selecting the affected metal on the first column and then selecting the “Smelter Not Listed” on the second column. You then will have the option to input any information from the remaining columns.
For smelters that are not listed on the CMRT, it is important to list as much information as possible. Our due diligence process will require us to reach out to these smelters and having as much information as possible will allow us to do.
PRODUCT INFORMATION (PRODUCT LIST TAB)
The Product List tab allows manufacturers to list products under the scope of this declaration. This section of the CMRT is mandatory if manufacturers selected Product (or List of Products) in the Company Information section.
Please note: Manufacturers are required to list product numbers in the Manufacturer’s Product Number column.
The Checker Tab allows manufacturers to verify if all the required information has been populated. It is the best way to ensure completion before submitting the CMRT.
- Fields in green — completed
- Fields in red — not completed
Look for the fields highlighted in red. The notes in Column C prompt you with what actions are required. The Hyperlinks to Source in Column D provide you with access to the fields that require completion. Please note: As the Checker is updated real-time, you can review it at any time while completing the template.
For additional information on Conflict Minerals, download a copy of Assent's eBook The Conflict Mineral Handbook: Your Guide to Compliance in 2019.