A1. Conflict minerals are:
Tantalum (columbite-tantalite or coltan) - used in electronics for capacitors
Tin (cassiterite) - used in most solder
Tungsten (wolframite) - may be found in lasers and chemical labs
Gold - many uses, but heavily used in printed circuit boards
Sometimes these are referred to as 3T's & G or 3TGs.
A2. These minerals are called out in The Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act), Section 1502. "Conflict" refers to the fact that these minerals, sourced in the
Republic of the Congo (DRC) or an adjoining country, may be financing conflict and related human
abuses in those regions. In addition to the DRC, the "covered countries" include: Angola, Burundi,
African Republic, and the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
--> The term "Conflict Minerals" applies to Tin, Tungsten, Tantalum and Gold regardless of where the
actually originate. Tin from Peru or Gold from Canada are still considered to be conflict minerals.
A3. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) was signed into U.S.
law in July 2010, and deals with major financial reforms, increasing liability among companies and
preventing adverse financial events due to unethical business practices. Conflict Minerals is called
Section 1502 of this Act.
A4. Publicly-traded companies on the U.S. stock exchange are affected. Registrants are required to
Special Disclosure (SD) related to Conflict Minerals and potentially provide a Conflict Minerals
this SD filing. Data for this filing must be gathered by suppliers and provided to these companies
Reasonable Country of Origin Inquiry (RCOI) process. Companies must file annually by the end of May
previous year's activities (e.g., May 2016 for 2015 reporting year).
A5. It is the process by which a company surveys its suppliers regarding the source of conflict
materials/products the suppliers have provided. The RCOI starts with the Conflict Minerals survey.
"How is data collected from suppliers?"
A6. Although a private company is not required to report about 3TGs on its own behalf, if it is a
to a publicly-traded company required to comply with the regulation and file the disclosure and
that private company should provide their sourcing information as requested by the publicly-traded
A7. customer expects suppliers to comply with its conflict minerals survey request and provide
on the survey form. (See "About the CMRT Survey Form" below.) As a condition of doing business with
customer, suppliers are required to provide information as per terms described in customer's P.O.
Conditions, its Supplier Code of Conduct, as well as in specific language in contracts or
A8. Data is collected through surveying suppliers, who in turn must survey their suppliers, and so
Customer has engaged with a service provider to assist with the surveying process. This service
SENSITEL. All survey-related requests are done through the email domain "customer.sensitel.com". A
authorizing Sensitel to request information from Customer's suppliers on its behalf is included in
survey request emails.
A9. The most-commonly used survey form is the "CMRT" (Conflict Minerals Reporting Template), which
received with customer's survey request. It is formulated and maintained by the CFSI (Conflict Free
Initiative), an organization founded by the EICC (Electronic Industry Citizenship Coalition) and
(Global e-Sustainability Initiative). Reference CFSI: http://www.conflictfreesourcing.org/about/.
survey is considered the industry standard and is used by most surveying companies.
A10. No, only the current version(s) of the CMRT is acceptable. We attach a current version (defined
version for the year's reporting) in our requests for you to fill out. However, any current year's
is acceptable. The CFSI may release several versions during the year, but the versions are usually
to lists or correction of functionality. Any current year version is acceptable: for the 2015
year, these would be CMRT versions beginning with "4" (e.g., 4.0, 4.01, etc.).
A11. The requirements for the CMRT are that it
Must be current year version as explained in Q10 above
Must be in the Excel format in which it was provided (.xls version, 1997-2003)
PDF versions or images are not acceptable
Must be in English (see Q12 below)
A12. The CMRT defaults to English, however, it is available in 8 additional languages. On the
tab, refer to the top box that says "English". A pull-down arrow on the lower right will allow the
to choose from the following languages:
Chinese ,French ,Spanish ,Japanese ,Portuguese ,Italian ,Korean ,German
Once a language is chosen, the following tabs are translated:
Instructions: this provides information on how to fill-in the declaration, smelter list and product
Declaration: Supplier makes declarations regarding use of conflict minerals
Smelter List: Supplier provides smelter information
Standard Smelter Names: Provided by the CFSI. These are smelters which are "known" by CFSI. These
have taken steps toward verifying themselves as conflict-free, but have not yet successfully
REMINDER: If you change the language to fill out the form, you must CHANGE IT BACK TO ENGLISH before
it back. Any non-English versions will be returned for correction.
A13. Yes. There is a list for each mineral. These lists are managed and updated by the CFSI and can
on their website at: http://www.conflictfreesourcing.org/conflict-free-smelter- refiner-lists/
These lists may be updated as often as monthly.
A14. Suppliers are encouraged to review the Instructions tab of the CMRT. In short, the requirements
The Declaration tab
The Company Information Section, including scope
If no 3TGs are used, see Q17.
If 3TGs are used, answer Questions 1 through 7, and A through J
The Smelter List tab
If 3TGs are used, provide smelter information
The Product List tab
Only if declared scope/reporting level (from Declaration tab) chosen is "Product (or List of
A15. Suppliers are encouraged to review the Instructions tab of the CMRT. In short, the The Checker
shows what information on the Declaration tab is missing. It is a good idea to review the Checker
to finalizing the CMRT and sending it to customer.
The results of the Checker are in two places on the CMRT:
On the Declaration tab at the top, just above the "Revision", indicating "1 or more required fields
On the Checker tab, fields requiring information are in red, and count of fields is in red text at
of the tab, directly to the left of the CFSI logo.
A16. Suppliers are encouraged to review the Instructions tab of the CMRT. In short, the No, only the
survey meeting the requirements is acceptable. See in Q10, Q11 and Q12. Do not send ROHS, REACH or
as these do not apply to conflict minerals.
The results of the Checker are in two places on the CMRT:
A17. Yes, this "no 3TG" information will be captured using the CMRT as well as ensure your status is
as "responded" versus "no response". A response fulfills your obligation to customer as per PO Ts&Cs
Supplier Code of Conduct.
If no 3TGs are used, the following sections of the CMRT Declaration should be filled in:
The Company Information Section, with fields highlighted in yellow and marked with an asterisk "*"
Questions 1 and 2 for all minerals
Once Questions 1 and 2 have been completed, the remainder of the questions should auto-populate and
A18. Yes, if you provide materials to customer that contain the minerals. If you are declaring no
per Q17 above, you do not need to answer these questions.
A19. All documents or communications should be sent back to the requesting email address