Conflict Minerals: Guidance for Supplier Scoping

 Scoping suppliers for conflict minerals compliance is fairly simple, but many companies find it daunting due to the volume of suppliers and/or a lack of data. If you are not sure where to start, you aren't alone. Every company is different, so it’s impossible to give specific instructions. These are some general suggestions for an approach I’ve often seen used successfully — just remember to consider how well this or any scoping process will work with your company and your specific situation.

In many cases, a good scoping method is to conduct an engineering assessment on each of your commodity types to determine which could contain tin, tungsten, tantalum, and gold (3TGs) as well as cobalt if you are also including that mineral in your program. If your analysis suggests a commodity type could contain one of these minerals, then include all of that commodity’s active suppliers in your communications and data requests. Record and eliminate any suppliers from your campaign who respond with documentation showing their products do not contain 3TGs.

If you have a large number of suppliers, you may want to conduct a series of engagements over time rather than attempting to reach all in-scope suppliers at once. However, some customers may balk at this approach and instead expect across-the-board data to be available. In these situations, it may be a good idea to also consider prioritization based on spending. After the original material analysis, use spending analysis to focus on suppliers whose products most strongly impact key customer products and/or correlate to the largest revenue volume. Over time you’ll want to communicate with all of your suppliers whose products could contain 3TGs — but if your supplier list is too long to tackle at once, this approach may help you prioritize until you have reached the point where you can successfully survey all relevant suppliers each year.

Article is current as of 2020-06-12.

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