Conflict Minerals
(3TG)
Tin, Tantalum, Tungsten, and Gold due diligence for manufacturers, brand owners, and importers. From supplier outreach to SEC-ready filing, fully managed.
Every client receives a detailed Conflict Minerals dashboard covering supplier response rates, smelter validation progress, RMAP audit status by smelter, 3TG mineral-level details, and country of origin data across their supply chain.
Supplier Collection Status
Smelter Verification Status
High-Risk Smelter Breakdown by Mineral
Smelters flagged as high-risk are those operating outside RMAP/RJC audit scope or sourcing from documented conflict-affected regions. These trigger escalation and conservative declaration logic downstream.
8 smelters flagged across 4 minerals. Gold carries the highest concentration of unverified and high-risk refiners. Conservative declarations applied to all affected supplier CMRTs.
DRC-Free Declaration Rate by Mineral
Conservative declaration logic applied. Reflects worst-case sourcing status across all supplier CMRTs. Minerals with high-risk smelters carry lower DRC-free rates.
Complete conflict minerals documentation including validated CMRTs, smelter verification reports, RCOI summaries, and SEC-ready filing support. Fixed-fee delivery with no scope creep.
- •Full CMRT collection, validation, and rollup across your supplier base
- •Smelter deduplication and RMAP conformance verification
- •Multi-wave supplier outreach targeting 85%+ response rates
- •Conservative declaration logic applied, not supplier optimism
- •SEC Form SD and Conflict Minerals Report preparation
- •Audit-ready documentation for regulatory and customer submissions
Who this applies to
- SEC-reporting companies where 3TG is necessary to product functionality
- EU importers of 3TG minerals or metals above threshold volumes
- Manufacturers whose customers require annual CMRT submissions
- Electronics, automotive, aerospace, and industrial suppliers
Scoping and Collection
Supplier list finalisation, scope determination, CMRT distribution, and multi-wave outreach with structured escalation logic for non-responders.
Validation and Analysis
CMRT validation against RMI standards, smelter deduplication, RMAP conformance checks, and conservative declaration rollup across all supplier data.
Reporting and Filing
SEC Form SD and Conflict Minerals Report preparation, customer submission packages, and audit documentation. File-ready by the SEC June deadline.
Annual SEC Disclosure
Annual filing obligation for public companies where 3TG is necessary to product functionality. Requires RCOI, supply chain due diligence, and Form SD submission by June 1.
EU Conflict Minerals Regulation
Due diligence obligations for EU importers above volume thresholds. Applies to importers of 3TG minerals, ores, and metals entering the EU market.
RMI Reporting Template
The Conflict Minerals Reporting Template, version 6.x, is the industry-standard instrument for supplier due diligence declarations and smelter reporting.
Due Diligence Guidance
The globally recognised framework for responsible supply chains. Compliance underpins defensible SEC reporting and OECD-aligned program documentation.
Low response rates
Unclear outreach and absent escalation logic. Most programs stall at 50-60% without structured follow-up sequences.
Unvalidated CMRTs
Accepting declarations without checking smelter lists, duplicates, or alignment with current RMI standards.
Wrong scope level
Company-level declarations when product-level or division-level reporting is required by SEC rules or OEM customers.
Optimistic declarations
Not applying conservative logic. Declarations that reflect supplier optimism rather than worst-case sourcing reality.
Annual-only mindset
Treating conflict minerals as a once-a-year exercise rather than a continuous program with active supplier data.
Audit-unready records
Documentation that cannot withstand SEC audit or customer review. No traceability, no version control, no OECD mapping.
Full program delivery.
Audit-ready outputs.
We run the entire annual cycle including scoping, collection, validation, and reporting. Every output is documented, defensible, and ready for customer review or regulatory audit.
- CMRT collection, validation, and rollup across your full supplier base
- Smelter identification, deduplication, and RMAP conformance verification
- Conservative declaration logic applied across all supplier-reported data
- Multi-wave outreach campaigns with structured escalation for non-responders
- SEC Form SD and Conflict Minerals Report preparation support
- Annual program management: scoping, collection, analysis, reporting
- Audit-ready documentation packages for customer and regulatory submissions
Run the full program with us
From supplier outreach to board-ready reporting. Fixed fees. Audit-ready outputs. No surprises.