Dealing with Supplier Push-Back Regarding the Disclosure of 3TGs in Products

Question Posed:

My supplier doesn’t think they need to disclose the use of 3TGs in their products, but I believe they are in scope. What should I do?

Answer Provided:

If you can show you’ve made reasonable inquiries to the reluctant supplier, that may be sufficient for your end-of-year disclosure. However, it is generally recommended to contact the supplier and explain that in order to align with industry standards, they should disclose material sources for 3TGs in the supply chain. This goes beyond U.S. Securities and Exchange Commission (SEC) reporting — companies around the globe, including those not directly reporting to the SEC for the purposes of Section 1502 of the Dodd-Frank Act, have responsible minerals programs and require supply chain transparency.


**Article contents valid as of 2019-03-18

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