Conflict Minerals Compliance: Reasonable Country of Origin Inquiry. Are you Gambling with the Cornerstone of Your Conflict Minerals Compliance Program?

If you have initiated your conflict minerals compliance program, you likely began your process by carefully filtering your products to identify those that may contain gold, tin, tantalum and tungsten (3TG) necessary to functionality or production. Based on this focused list, you are now ready to initiate a Reasonable Country of Origin Inquiry (RCOI) by working with companies throughout your supply chain. Depending on the number of products requiring investigation and the complexity of the associated supply chains, a 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.

Click here to read more about RCOI and the essential Elements for tracing Conflict Minerals.