We are hearing on an increasingly frequent basis about suppliers providing names of facilities that are reportedly 3TG smelters or refiners, but are not included in the EISS-GeSI verified smelter listing that is included in the Conflict Minerals Common Reporting Template.
What does this mean, and what should you do?
We had a conversation last week with someone intimately familiar with the CFSI and the verified smelter list who offered some thoughts.
First off, the list of verified smelters and refiners (those listed in the “Standard Smelter Names” tab of the Template) is not exhaustive. This is indicated in the header on that page, which states that the list “does not represent … all smelters worldwide.” The list is based on those that have been identified by EICC, GeSI and CFSI members primarily within the electronics supply chain, although the gold list relies heavily on the jewelry and gold industries.
Those in industrial and commercial sectors that have identified additional smelters not included in the CFSI Standard Smelter List are faced with the question of what to do with these. We have seen companies going in different directions, such as:
- Taking a position that smelters/refiners not on the verified list are not valid for the 2013 filing but they will be evaluated further for the 2014 filing.
- Reporting them in the smelter/refiner list of the 2013 disclosure with conflict status of “Unknown”.
- Conducting stand-alone verification efforts, then reporting or excluding them in the 2013 filing based on the results.
Regardless of the decision, companies who find unlisted smelters or refiners should report these to CFSI for further investigation and possible inclusion in the upcoming CMRT 3.0 and associated on-line smelter/refiner list.