Conflict Minerals Intertek Managing Conflict Minerals Requirements

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1 Conflict Minerals Intertek Managing Conflict Minerals Requirements Matt Quinn Chemical Services 1

2 Our Heritage Today Caleb Brett founds a marine surveying business Thomas Edison establishes what is later renamed as the Electrical Testing Laboratories (ETL) Virginius Daniel Moody establishes Moody Engineering for construction and electrical engineering projects Labtest establishes the first commercial consumer goods testing facility in Hong Kong Labtest establishes the first commercial testing laboratory in China Intertek and Moody International join forces Intertek Today: Valued Quality. Delivered. 2

3 An Extensive Global Network More than 1,000 laboratories and offices Over 38,000 people More than 100 countries FTSE 100 company in the Support Services sector Revenue generation of over 2bn in

4 Intertek at a Glance Our organisation Products Industry Commodities Industries we operate in Aerospace & Automotive Building Products Chemical Consumer Goods & Retailers Electrical & Electronic Energy Food & Agriculture Government & Institutions IT & Telecom Industrial Medical & Pharmaceutical Minerals Petroleum Toys, Games & Hardlines Textile, Apparel & Footwear What we do Testing Inspection Certification Auditing Outsourcing Advisory Training Quality Assurance 4

5 Overview of Dodd-Frank S1502 The Basics On August 22, 2012, the Securities and Exchange Commission (SEC) adopted S1502 of the Dodd-Frank Act Known as the Conflict Minerals Act. The regulation is intended to act as a catalyst to avert direct or indirect financing of conflict in the Democratic Republic of Congo (DRC) and 9 neighboring countries through pressuring companies to disclose origin of materials used in the supply chain. The Conflict Minerals Act covers the 3T s & G : Tin Tungsten Tantalum Gold 5

6 Overview of Dodd-Frank S1502 Impact on Companies Companies that are affected: Issuers - Companies who file under Exchange Act (SEC) Manufacture or contract to manufacture products where 3T&G are necessary for the functionality or production of the finished product If the minerals are intentionally added at any point. Indirectly will affect most supply chains that sell to publically traded organizations. No de-minimis clause 6

7 Why Section 1502? Exploitation of conflict minerals originating in the Democratic Republic of Congo (DRC) is helping to finance conflict with extreme levels of violence in eastern DRC. The conflict has claimed >5 million lives since late 1990s. The DRC is #186 of 187 countries on UNDP s Human Development Index. (2014) Mineral Metal Derivatives Share of Global Production from DRC Columbite-tantalite (coltan) Tantalum ~15-20% Cassiterite Tin ~5% Wolframite Tungsten ~2% Gold Gold ~2% 7

8 The 3T+G Supply Chain 1,000s Mines Trading Houses In-Country Bag and Tag Systems Solutions for Hope (SfH): Tech sector initiative launched in July 2011 to create an initial flow of conflict-free tantalum from the DRC 100s Smelter / Refiner RCOI drives industry to get down to this level; Companies can piggy back onto Industry initiatives, such as the Conflict Free Smelter Program 1,000s Product/Component Manufacturer OEM Companies conduct self assessment questionnaires, RCOI and Due Diligence Companies have the most impact further downstream. 8

9 What does the SEC Require for Compliance? The final ruling requires Issuers to conduct the following: 1. Determine Applicability Understand whether you fall under scope of the requirements and whether your products contain Conflict Minerals that are necessary to the functionality or production of your product. 2. Determine Whether Conflict Minerals Originated in the Democratic Republic of the Congo or Adjoining Countries and the Resulting Disclosure Reasonable Country of Origin Inquiry (Risk Assessment) 3. Supply Chain Due Diligence and Conflict Minerals Report (if required) Smelter/Refiner Due Diligence Traceability Audits Creation of Form SD/Conflict Minerals Report 9

10 Step 1: Determining Applicability Companies will need to determine whether their products contain Conflict Minerals and whether they are necessary: 1. To the Functionality of the Product 2. To the Production of the Product This Determination should also be carried out by the private organizations within the supply chain. This will account for deviations in product assessments and focus RCOI efforts. 10

11 Conflict Minerals Usage Electronic Hardware Tantalum Tin Tungsten Gold PCB Solders Component lead frames, contacts, and connectors Processors and chipsets Capacitors Hard disk drive LCD screens and displays Power supplies and adaptors Speakers Cameras Batteries Cables Mechanical Parts 11

12 Determining Necessary to Functionality of Product Functionality of the Product issuers will need to consider the following: If the conflict mineral was added intentionally to the product or a component of the product. Does not have to be the issuer adding the CM. If the mineral is needed for one function, use, or purpose of the finished product. (Example: Smart Phone) Whether the conflict mineral is incorporated for purposes of ornamentation, decoration, or embellishment. 12

13 Determining Necessary to Production of Product Production of the Product issuers will need to consider the following: If the conflict mineral was intentionally included in the production process. This does not include tools, machines or equipment that are used during the production process. Whether the conflict Mineral is required for the production of the product. Whether Conflict Mineral was included in the product. Catalysts that are used during the manufacturing process that do not remain in the product are exempt. 13

14 Step 2: Reasonable Country of Origin Inquiry (RCOI) If products contain necessary Conflict Minerals, the Issuers are required to carry out RCOI to determine if they are sourced from the Covered Countries. Final ruling does not specify what steps and outcomes are necessary to satisfy the reasonable country of origin inquiry requirement as it depends on each issuer s particular facts and circumstances RCOI process should be aligned with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected And High-Risk Areas Provides Country of origin information as well as provides risk information on the individual supplier. 14

15 Tools to Carry Out RCOI Process Conflict Free Sourcing Initiative (CFSI) has created the Conflict Mineral Reporting Template (CMRT) to standardize data collection Records suppliers Conflict Mineral information and Smelter/Refiners found in the supply chain. IPC Conflict Minerals Data Exchange Standard Establishes Requirements for Suppliers and their Customers Need to determine which level of Declaration you will be collecting: Corporate vs. Product Companies will be moving towards collecting Product level declarations in order to help stream line Due Diligence phase. 15

16 How is the RCOI Carried Out? How do companies conduct a reasonable country-of-origin inquiry? Supplier Self Assessments provide trickle-down effect, for easier risk filtering. For example, the CFSI Conflict Mineral Reporting Template Direct Supplier Supplier ( User ) Send Back Aggregated/ Completed Templates Beginning: Send Instructions and Questionnaire End: Send Back Aggregated/Completed Templates Sub- Supplier Direct Supplier The Company Send Back Aggregated/Completed Templates 16

17 RCOI Process Data Validation Data validation needs to occur on CMRTs from the supplier. Do the responses provided for each of the questions contradict each other? Example: Do all 3TGs originate from recycled sources, answers Yes for Tantalum, but only has collected 50% of CMRTs from their suppliers. Have the suppliers provided valid Smelter/Refiner information? Compare provided information to CFSI, LBMA, and State Department List. Trying to validate data manually may be very difficult. Automating this process will save time and mitigate risk of errors. 17

18 RCOI Process Data Roll-Up Once Data is collected the smelter list should be amalgamated and reviewed to determined if the supply chain contains any 3TGs from the DRC or covered countries. This will dictate whether you need to move onto Step 3: Due Diligence. Understanding customer responses to questions A-J will help determine risk of suppliers. Will need to conduct traceability audit on some of the higher risk suppliers. Private companies will roll-up data into corporate CMRT and provide to customers. 18

19 Due Diligence: Countries of Risk Companies should Red Flag suppliers knowingly sourcing minerals in the DRC or surrounding countries and suppliers who don t know and thus are unable to determine the mineral(s) origin Central African Republic Sudan Uganda Rwanda Burundi Tanzania Zambia Congo Democratic Republic of Congo Angola 19

20 RCOI: Intertek s Supplier Management Solution Identifies HIGH RISK SUPPLIERS AND SMELTERS/REFINERS HOUSES AND ANLALYZES SUPPLIER PROFILES through supplier submitted CMRTs Facilitates Process by: VALIDATES CMRT RESPONSES VALIDATES SMELTERS/REFINERS COMPILES SMELTER LIST POPULATES CORPORATE / PRODUCT CMRT LOGS ALL ACTIVITY FOR AUDIT TRAIL PURPOSES 20

21 What Are My Responsibilities After My RCOI is Complete? There are two potential scenarios that are dictated by the CMRT data you collected: If no 3TGs from the Covered countries are present or they came from recycled or scrap sources, you submit a Form SD describing your RCOI process and how you came to this determination. (Annually) If Issuers determine (or have reason to believe) that necessary 3TGs are in the supply chain and are from the covered countries, Issuers are required to move to Step 3. 21

22 Step 3: Due Diligence and Conflict Minerals Report Issuers are required to conduct due diligence on the source and chain of custody of the Conflict Minerals found in the supply chain sourced from the covered countries. Due diligence process must be based on nationally or internationally recognized standards as well as the Issuers individual facts and circumstances. OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected And High-Risk Areas Misconception that the RCOI is part of the due diligence process. This is not the case. 22

23 Step 3: Due Diligence and Conflict Minerals Report Cont d The purpose of the due diligence is to determine if the Issuers 3T&Gs are conflict free or not. Steps can include, but not limited to: Validating unknown smelters / refiners Reviewing validated smelters / refiners and identifying who has been deemed to be Conflict Free through auditing CFSI Conflict Free Smelter Program Putting forth a reasonable effort in determining risk of remaining smelters / refiners as to whether they are Conflict Free or not. Verifying suppliers information through traceability audits. 23

24 OECD Guidelines - Overview OECD Guidelines provides a framework that companies can use to determine and mitigate risk of sourcing Conflict Minerals from the covered countries. 5 Steps: Establish Strong management systems Identify and assess risk in the supply chain Design and implement a strategy to respond to identified risks Carry out independent third-party audit of smelters/refiners due diligence practices Report annually on supply chain due diligence 24

25 OECD Guidelines Developing Internal Systems 1. Establish Strong Company Management Systems Create appropriate internal stakeholder team Create a company policy and statement regarding your conflict minerals position and your expectations of your suppliers going forward. This should be communicated internally as well as externally. Create RCOI process to identify 3TG s and Conflict Minerals sourced from the covered countries. Ensure you work Conflict Minerals into your procurement contracts with your suppliers. Implement internal system to identify possible risks within the supply chain. 25

26 OECD Guidelines RCOI and Responding to Identified Risks 2. Identify and Assess Risk in the Supply Chain Reasonable Country of Origin Inquiry and Traceability Audits 3. Design and Implement a strategy to respond to identified risks Reporting of risk assessment to management steering committee. Create a Process for dealing with at risk suppliers or Smelters/Refiners Strive for year-over-year improvement of your internal process and policies. Risk Mitigation. 26

27 OECD Guidelines Auditing Due Diligence and Reporting 4. Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain SEC Final Ruling initially required Conflict Free declarations in Conflict Minerals Report to go through an Independent Private Sector Audit (IPSA). This has changed. 5. Report on supply chain due diligence Form SD / Conflict Minerals Report 27

28 Utilizing Industry Associations to Help with Due Diligence Utilizing Industry Associations and groups will facilitate Due Diligence process with determining Conflict Mineral Status of Smelters/Refiners. Are they actually a Smelter/Refiner? Have they been audited and deemed DRC Conflict Free Conflict Free Sourcing Initiative (CFSI) Joint effort of Electronic Industry Citizenship Coalition (EICC) and Global e-sustainability Initiative (GeSI) Audit Smelters and Refiners to determine Conflict Free 45 Tantalum; 42 Tin; 15 Tungsten; 70 Gold Created and Maintain CMRT CFSI, LBMA and State Department lists can be used to identify valid Smelters/Refiners. They are not exhaustive. 28

29 What Do The Outcomes of My Due Diligence Mean? (Final Ruling) If Issuer finds that Conflict Minerals are not sourced from covered countries or are from recycled or scrap sources, they must describe their due diligence in the Form SD. Not required to submit Conflict Minerals Report If Issuer finds that Conflict Minerals are sourced from Covered Countries and not from recycled and scrap sources, they must file a Conflict Minerals Report as an exhibit of their Form SD. If some Issuers are not able to determine whether their products are conflict free or not, they can declare as DRC Conflict Undeterminable. Past this filing only smaller reporting companies (less than 75 million in outstanding shares owned by the public) allowed until 2016 data year (2017 filing). 29

30 Conflict Minerals Report (CMR) The final ruling states that a CMR must include the following: The country of origin of those conflict minerals Any effort made to determine the mine or location of origin with the greatest possible specificity The facilities used to process those conflict minerals, such as the smelter or refinery through with the issuer s minerals pass A description of any products that are not DRC conflict free. Generally companies will use the OECD Guidelines as a framework for their CMR. Does not have to be overly specific, but should address the different pieces. 30

31 Conflict Minerals Report (CMR) Cont d Under the final ruling if you want to claim DRC Conflict Free you will need to have an IPSA conducted on Due Diligence. Audit does not determine whether you are Conflict Free or not. Looks at your process and determines whether you followed it. 31

32 Change in CMR and IPSA Requirements Court of Appeals has ruled that declaration of Conflict Minerals violates the First Amendment. In appeal process. Confirmed by Court of Appeal for the D.C. Circuit reaffirmed it s decision (Aug 18) SEC has issued statement on the following changes: No company is required to describe its products as DRC conflict free, not been found to be DRC conflict free or DRC conflict undeterminable. If a company has products under scope it would not have to identify the products as DRC conflict undeterminable or not found to be DRC conflict free, but should disclose, for those products, the facilities used to produce the conflict minerals, the country of origin of the minerals and the efforts to determine the mine or location of origin. 32

33 Change in CMR and IPSA Requirements Cont d Pending further action, an IPSA will not be required unless a company voluntarily elects to describe a product as DRC conflict free in its Conflict Minerals Report #.VP7rPvnF_aU Although IPSA s are not currently required, there will be organizations that will still move forward with these audits in an effort to declare DRC Conflict Free. 33

34 What Does All This Mean to the Supply Chain? Issuers are looking to the supply chain to provide corporate and Smelter/Refiner information in order to determine if they have any Conflict Minerals in their Supply Chain. Looking at Private Companies to implement the necessary risk mitigation processes. Now that the Issuers have (almost) two filings under their belt, the push back on problem CMRTs will most likely increase. Some Issuers are readying themselves for audits and will need to tighten the information from the suppliers. Increased transparency. Be prepared to provide CMRT on product level. Issuers want to minimize due diligence efforts. Be prepared to show progress year-over-year. They are looking for you to improve your internal program. 34

35 Summary of US Conflict Minerals Determining product applicability will help streamline your RCOI efforts. Align your program with OECD Guidelines to ensure you are developing an acceptable program. Work with industry associations where possible to help with Due Diligence efforts. Although IPSAs are not currently required, companies will still be conducting them to ensure Conflict Free Status. 35

36 EU Conflict Minerals First Vote Info Previous voluntary conditions have been removed and has moved towards mandatory requirements. Smelter and Refiners will be required to do through a 3 rd party audit. Is not limited to Issuers. Can affect all EU Manufacturers (~880,000 businesses). Companies must provide information on the steps they take to identify and address risks in their supply chains for the minerals and metals concerned. It currently has a global scope. Not just limited to DRC Still open and requirements can change. 36

37 Valued Quality. Delivered. 37

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