Efficiently Validate Collected Smelter Information
The SEC Rule Dodd-Frank 1502 requires issuer’s Conflict Minerals Report to include a description of the facilities used to process conflict minerals and the country of origin stating that the facilities refer to the smelter or refiners in an issuer’s supply chain. But how do you efficiently validate all that collected smelter information?
SMELTER ENGAGEMENT AND EDUCATIONLeveraging a 24-hour, 7 day a week Supplier Engagement Team with real people here in Carlsbad, CA, combined with the power of an analytics platform to ensure timely, accurate, and engaging outreach.
SMELTER RESEARCH AND VALIDATIONObtaining sourcing and due diligence information from suppliers.
SMELTER STATUS AND VALIDATIONIdentifying your Smelters, by metal and/or product, verifies their status and certifications, and provides the documentation necessary to answer requests and comply with regulations.
Identifying the source of your supplied metals is the main purpose of Conflict Minerals Reporting and Compliance. A Smelter is usually the first stop for raw materials once they have been mined or recycled by the provider. We can help you identify your Smelters, by metal and/or product, verify their status and certifications, and provide the documentation necessary to answer requests and comply with regulations. Verify your Smelters once, post your certified results, and reuse this certification to respond to any future requests.
Benefits of a Smelter Verification Program
- Conflict Minerals Compliance Programs require audit-ready data
- Issuers and suppliers require smelter due diligence to comply, determine problematic sourcing and mitigate risk
- Suppliers must submit valid smelter data
- Acquire Supplier-provided Smelters
- Smelters verified against SI Smelter Database
- Receive Quarterly Smelter Reports
- SI Certification
- Smelter Research and Validation
- Database Reconciliation
- Smelter Engagement and Education
- Training and Online Assistance
- SI Certification
Frequently Asked Questions
What is a smelter?
A Smelter is usually the first stop for raw materials once they have been mined or recycled by the provider. We can help you identify your Smelters, by metal and/or product, verify their status and certifications, and provide the documentation necessary to answer requests and comply with regulations.
What do companies who are non-issuers risk by not reporting or responding to smelter information requests from customers?
Many non-issuers who thought they wouldn’t have to respond to their customers, are seeing increasing customer requests for additional and more in-depth smelter information. Companies who are non-issuers who fail to respond are at risk of losing revenues or violating contract terms, and reputational damage depending on the product and level of importance that the company’s customer place on this issue. .
How often should we be verifying smelter information with our factories? How can we verify the information that we are given from our factories is correct?
We’d recommend that the information be verified at least before each new Conflict Mineral Reporting Template (CMRT) is prepared/submitted. The situation you describe is also a good example of why having an electronic or web-based solution for data collection makes this process significantly more manageable. Source Intelligence has an expansive data warehouse of supplier declarations and public, non-public smelter/refiner information.
Who is considered an Issuer, and who is considered a Non-Issuer?
If you are a publicly traded company as defined by the Securities Exchange Commission (SEC)–specifically the company files reports with the SEC under Sections 13(a) or 15(d) of the Exchange Act – you are considered an Issuer. If your company is not publically traded in the United States, you are considered a Non-Issuer. The Securities and Exchange Commission (SEC) may not directly regulate non-issuers; however, many private and non-U.S. publically traded companies will be impacted by Dodd-Frank 1502 as requests for information could come from both upstream and downstream customers that are required to report with the SEC.