Depending on the number of products requiring investigation and the complexity of the associated supply chains, a Reasonable Country of Origin Inquiry (RCOI) could involve hundreds or even thousands of telephone and email inquiries, data requests, data files and other supporting documents. To effectively highlight areas of risk and provide auditable evidence of your due diligence process, these efforts and the resulting data must be well-organized, and continuously reviewed and assessed. Key issues to consider throughout the process are supplier response rates and requests for confidentiality, missing and erroneous data, and discovery of red flags, which warrant further investigation.
The Reasonable Country of Origin Inquiry (RCOI) conducted by your organization will be a cornerstone of your Conflict Minerals compliance program. Not only will it require a significant amount of labor and other resources, but it should be viewed as your “first pass” at identifying Conflict Minerals risks hidden within your supply chain. Successfully identifying these risks will require a thorough, well-organized system of data collection, and reasoned review of the collected information. The number of products and suppliers passed to the Due Diligence process will subsequently impact the level of work required in auditing and reporting, highlighting the criticality of a RCOI done right the first time.