Conflict Minerals & Responsible Sourcing

Conflict Minerals (3TG)

Whether you're responding to customer CMRT requests or building your own due diligence program, The 3TGs brings deep operational expertise, from smelter-level validation to defensible declarations.

• CMRT collection, validation, and rollup
• Smelter identification, deduplication, and RMAP conformance verification
• Conservative declaration logic: declarations reflect worst-case reality, not supplier optimism
• SEC Form SD and Conflict Minerals Report preparation support
• Annual program cycle management: scoping, collection, analysis, reporting

Extended Minerals

Supply chain due diligence is expanding beyond 3TG. Cobalt, mica, and other minerals face growing scrutiny from regulators and responsible sourcing initiatives.

• EMRT deployment and collection
• Cobalt and mica supply chain mapping
• Alignment with OECD Due Diligence Guidance
• Integration of extended minerals into existing 3TG programs

Supplier Engagement & Training

Your compliance data is only as good as your supplier response rates. Low engagement, bad data, and stalled campaigns cost you audit readiness and market access. The 3TGs fixes that.

• Multi-wave campaign design with defined escalation triggers
• Supplier communication drafting: requests, reminders, escalation notices
• Response tracking, follow-up sequencing, non-responder management
• Executive escalation strategies for critical suppliers
• Supplier segmentation by risk tier, spend, and regulatory exposure

• CMRT/EMRT completeness and accuracy reviews
• Smelter list validation against RMI conformant smelter database
• Cross-referencing declarations against known material compositions
• Flagging inconsistencies and applying conservative declaration logic
• Data packaging for customer submissions and audit readiness

• Supplier onboarding guides for CMRT, EMRT, and disclosure forms
• Live and recorded training sessions on regulatory requirements
• FAQ documentation and step-by-step submission guides
• Tailored education by supplier tier (Tier 1 vs. sub-tier)

ESG & Responsible Sourcing Alignment

Minerals due diligence feeds directly into your broader ESG posture. The 3TGs helps you connect program outputs to investor-facing ESG disclosures and customer sustainability questionnaires.

• Program design aligned to OECD five-step framework
• Mapping due diligence outputs to ESG reporting frameworks (GRI, SASB)
• Smelter and refiner risk assessment against CAHRAs
• Policy development for responsible minerals sourcing
• Supporting customer sustainability questionnaire responses with program data

Mineral Sourcing Advisory

Responsible sourcing is shifting from a compliance exercise to a strategic differentiator. Companies that can demonstrate clean, traceable mineral supply chains win preferred supplier status, satisfy investor ESG screens, and reduce regulatory exposure before mandates hit.

• Supply chain mapping from finished product to smelter/refiner level
• Risk assessment of sourcing geographies against CAHRAs and sanctions lists
• Alternative sourcing pathway identification for high-risk minerals
• Sourcing policy development aligned to customer and investor expectations
• Ongoing monitoring and reporting on sourcing risk indicators

Human Trafficking & Slavery

Modern slavery legislation is expanding globally. Companies are increasingly required to assess forced labor risks in their supply chains, publish transparency statements, and demonstrate active due diligence. The 3TGs helps you build a defensible program that addresses legal obligations and customer expectations.

• Supply chain risk assessment for forced labor and human trafficking indicators
• Supplier questionnaire design, distribution, and follow-up for social compliance data
• Gap analysis against UK Modern Slavery Act, U.S. UFLPA, EU CSDDD, and other frameworks
• Modern slavery transparency statement preparation and review
• Supplier code of conduct development and implementation support
• Corrective action planning and remediation tracking for identified risks
• Documentation and audit trail for customer and regulatory submissions