Question: Does the company describe having a supply chain transparency, chain of custody, or traceability system in place?
Answer:
Yes
7961664
2018
Unverified - Added by Steward
"We rely on our suppliers to provide information on the origin of 3TG contained in components and parts included in our products. The identification of suppliers that are relevant to us under the CM Rule involves different geographic regions, business areas and production sites throughout our organization. The CM Team plays a leading role in coordinating the supplier identification efforts. Suppliers who were identified in 2018 to be relevant for our RCOI process were identified on the basis of criteria such as the level of purchasing activities with such supplier and the likelihood that the items furnished by the supplier contain 3TG. The processes performed and described in this Report cover more than 95% of our worldwide supply chain activities relevant to 3TG. In our annual RCOI process for 2018, we reviewed suppliers identified to be relevant under the above-mentioned identification criteria in an effort to determine the origin of the 3TG in our products. We analyzed and followed up with inquiries as we deemed appropriate where the analysis of our survey results indicated further information may be desirable. We do not have a direct relationship with 3TG smelters and refiners, and we do not perform or direct audits of these entities within our supply chain." p. 3