2018
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IBM (International Business Machines Corporation)
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Step 1 Information Review (Step 2.A.1)
Has the company established a system to accurately review the information they gathered in Step 1?
"- Requested IBM’s in-scope direct suppliers to identify SORs and related Conflict Minerals information through the use of the CMRT.
- Reviewed the information provided in the CMRTs against IBM’s validation criteria.
- Managed collection of CMRTs and tracked status of supplier responses.
- Analyzed the CMRTs for completeness and accuracy, and, when appropriate, communicated errors and actions required to in-scope direct suppliers.
- Used RMI Compliant Smelter Sourcing Information and other research to ascertain whether any Conflict Minerals in the Covered Products may have originated in the Covered Countries.
- Compared SORs identified by the in-scope direct suppliers against RMI information to determine valid SORs and their RMAP status; also checked the status of SORs against LBMA and RJC CoC information.
- Engaged a third-party consultant to research SORs identified as sourcing Conflict Minerals from Covered Countries."