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Conflict Minerals Due Diligence (Dodd-Frank 1502) Checklist
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Structure conflict minerals due diligence for tin, tungsten, tantalum, and gold following the OECD five-step framework and SEC reporting requirements.
Dodd-Frank Section 1502OECD Due Diligence GuidanceSEC Form SD
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Management Systems
- Has a conflict minerals policy consistent with the OECD Guidance been adopted and communicated? *
- Is there an internal management structure with assigned responsibility for the due diligence program? *
- Is a system in place to maintain records and engage with suppliers on 3TG? *
Reasonable Country of Origin Inquiry
- Has a Reasonable Country of Origin Inquiry (RCOI) been conducted to determine if 3TG may originate from covered countries? *
- Are products containing tin, tungsten, tantalum, or gold necessary to functionality or production identified? *
- Is the supplier survey conducted using a recognized tool such as the CMRT? *
Risk Identification & Response
- Have smelters and refiners in the supply chain been identified? *
- Are identified smelters checked against conformant lists (e.g., RMAP)? *
- Is a risk management plan in place to respond to identified red flags? *
- Is an independent third-party audit of supply chain due diligence obtained where required? *
Reporting
- Is a Conflict Minerals Report prepared where products are not DRC conflict free or undeterminable? *
- Is Form SD filed with the SEC by the annual deadline? *
- Are due diligence measures and results publicly disclosed on the company website? *
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