RCS Global today published an article discussing their general findings from conducting conflict minerals audits of Asian suppliers. The audits were intended to verify the statements, determinations and data presented to customers in the suppliers’ CMRTs. RCS’ observations may not be surprising: material/significant gaps were identified in the processes used by the suppliers to determine the product content, scope and smelter/refiner lists. We have previously commented on our views and concerns about reliance on supplier CMRT information. RCS’ efforts in the field fully validate our own observations.
We highly recommend reading RCS’ post and giving it due consideration with regard to your company’s supplier data and the resulting SEC filings/determinations. It may also be worthwhile to reassess supplier risk assessment criteria and CMRT review processes. Finally, perhaps the time has come to explore avenues for more fully validating the CMRT data, which should include a form of conflict minerals auditing of suppliers.