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What overall status did the company report in relation to Conflict Minerals?
Designed by
Amnesty International+image
United Kingdom
Metric Type
Researched
Value Type
Category
Unit
Range
Options
DRC Conflict Free
Not Been Found to Be DRC Conflict Free
DRC Conflict Undeterminable
Research Policy
Community Assessed
Report Type
Conflict Minerals Report

The following comes from the  Securities and Exchange Commission's |Conflict Minerals Fact Sheet:

What Must Be Included in the Conflict Minerals Report:

Under the final rule, companies that are required to file a Conflict Minerals Report (CMR) must exercise due diligence on the source and chain of custody of their conflict minerals. The due diligence measures must conform to a nationally or internationally recognised due diligence framework, such as the due diligence guidance approved by the Organisation for Economic Co-operation and Development (OECD).

DRC Conflict Free — If a company determines that its products are “Democratic Republic of Congo conflict free” — that is the minerals may originate from the covered countries but did not finance or benefit armed groups — then the company must undertake the following audit and certification requirements:

  • Obtain an independent private sector audit of its Conflict Minerals Report
  • Certify that it obtained such an audit.
  • Include the audit report as part of the Conflict Minerals Report.
  • Identify the auditor.

Not Been Found to Be “DRC Conflict Free” — If a company’s products have not been found to be “DRC conflict free,” then the company in addition to the audit and certification requirements must describe the following in its Conflict Minerals Report:

  • The products manufactured or contracted to be manufactured that have not been found to be “DRC conflict free.”
  • The facilities used to process the conflict minerals in those products.
  • The country of origin of the conflict minerals in those products.
  • The efforts to determine the mine or location of origin with the greatest possible specificity.

DRC Conflict Undeterminable — For a temporary two-year period (or four-year period for smaller reporting companies), if the company is unable to determine whether the minerals in its products originated in the covered countries or financed or benefited armed groups in those countries, then those products are considered “DRC conflict undeterminable.”

In that case, the company must describe the following in its Conflict Minerals Report:

  • Its products manufactured or contracted to be manufactured that are “DRC conflict undeterminable.”
  • The facilities used to process the conflict minerals in those products, if known.
  • The country of origin of the conflict minerals in those products, if known.
  • The efforts to determine the mine or location of origin with the greatest possible specificity.
  • The steps it has taken or will take, if any, since the end of the period covered in its most recent Conflict Minerals Report to mitigate the risk that its necessary conflict minerals benefit armed groups, including any steps to improve due diligence.

For those products that are “DRC conflict undeterminable,” the company is not required to obtain an independent private sector audit of the Conflict Minerals Report regarding the conflict minerals in those products.


Methodology

The company's 'specialised disclosure' (SD) filing should include a statement of how they view their current status with regards to conflict minerals. This statement determines which additional information the company should report. Search the report for the Democratic Republic of Congo and its abbreviated acronym DRC.

The language used in the filing should be a close match for one of the following categories* (please select one these as a value):

  • DRC Conflict Free  if this value applies, note in a comment to the value which auditor provided the certification.
  • Not Been Found to Be "DRC Conflict Free"
  • DRC Conflict Undeterminable

 *If unclear please add the relevant quote as a comment to the value.