Conflict minerals: Frequently asked questions

Q1. What are "conflict minerals" or "3TGs?"
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.

Q2. What makes them "conflict" minerals?
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 Democratic Republic of the Congo (DRC) or an adjoining country, may be financing conflict and related human rights abuses in those regions. In addition to the DRC, the "covered countries" include: Angola, Burundi, Central 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.

Q3. What is The Dodd-Frank Act?
A3. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) was signed into U.S. federal law in July 2010, and deals with major financial reforms, increasing liability among companies and aimed at preventing adverse financial events due to unethical business practices. Conflict Minerals is called out in Section 1502 of this Act.

Q4. Who must comply with the Dodd-Frank Act, Section 1502?
A4. Publicly-traded companies on the U.S. stock exchange are affected. Registrants are required to file a Special Disclosure (SD) related to Conflict Minerals and potentially provide a Conflict Minerals Report with this SD filing. Data for this filing must be gathered by suppliers and provided to these companies through a Reasonable Country of Origin Inquiry (RCOI) process. Companies must file annually by the end of May for the previous year's activities (e.g., May 2016 for 2015 reporting year).

Q5. What is a Reasonable Country of Origin Inquiry (RCOI)?
A5. It is the process by which a company surveys its suppliers regarding the source of conflict minerals in materials/products the suppliers have provided. The RCOI starts with the Conflict Minerals survey. Refer to "How is data collected from suppliers?"

Q6. How does this Conflict Minerals reporting requirement apply to private companies?
A6. Although a private company is not required to report about 3TGs on its own behalf, if it is a supplier to a publicly-traded company required to comply with the regulation and file the disclosure and report, then that private company should provide their sourcing information as requested by the publicly-traded company.

Q7. What does customer expect from its suppliers?
A7. customer expects suppliers to comply with its conflict minerals survey request and provide information 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. Terms and Conditions, its Supplier Code of Conduct, as well as in specific language in contracts or agreements.

Q8. How is data collected from suppliers?
A8. Data is collected through surveying suppliers, who in turn must survey their suppliers, and so on.
Customer has engaged with a service provider to assist with the surveying process. This service provider is SENSITEL. All survey-related requests are done through the email domain "customer.sensitel.com". A letter authorizing Sensitel to request information from Customer's suppliers on its behalf is included in the survey request emails.

Q9. What is a "CMRT"?
A9. The most-commonly used survey form is the "CMRT" (Conflict Minerals Reporting Template), which you have received with customer's survey request. It is formulated and maintained by the CFSI (Conflict Free Sourcing Initiative), an organization founded by the EICC (Electronic Industry Citizenship Coalition) and GeSI (Global e-Sustainability Initiative). Reference CFSI: http://www.conflictfreesourcing.org/about/. This survey is considered the industry standard and is used by most surveying companies.

Q10. Can a previous year's CMRT be resubmitted to customer?
A10. No, only the current version(s) of the CMRT is acceptable. We attach a current version (defined as the version for the year's reporting) in our requests for you to fill out. However, any current year's version is acceptable. The CFSI may release several versions during the year, but the versions are usually revisions to lists or correction of functionality. Any current year version is acceptable: for the 2015 reporting year, these would be CMRT versions beginning with "4" (e.g., 4.0, 4.01, etc.).

Q11. What are the requirements for the CMRT to be acceptable to customer?
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)

Q12. Is the CMRT available in languages other than English?
A12. The CMRT defaults to English, however, it is available in 8 additional languages. On the "Declaration" tab, refer to the top box that says "English". A pull-down arrow on the lower right will allow the supplier 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 list
  • Definitions
  • 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 smelters have taken steps toward verifying themselves as conflict-free, but have not yet successfully completed the process.
  • Checker
  • Product List
REMINDER: If you change the language to fill out the form, you must CHANGE IT BACK TO ENGLISH before sending it back. Any non-English versions will be returned for correction.

Q13. Is there a list of conflict-free smelters?
A13. Yes. There is a list for each mineral. These lists are managed and updated by the CFSI and can be found on their website at: http://www.conflictfreesourcing.org/conflict-free-smelter- refiner-lists/
These lists may be updated as often as monthly.

Q14. What parts of the CMRT need to be filled out?
A14. Suppliers are encouraged to review the Instructions tab of the CMRT. In short, the requirements are:

  • 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 Products)"

Q15. What is the "Checker" tab on the CMRT?
A15. Suppliers are encouraged to review the Instructions tab of the CMRT. In short, the The Checker tab shows what information on the Declaration tab is missing. It is a good idea to review the Checker tab prior 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 need to be populated"
  • On the Checker tab, fields requiring information are in red, and count of fields is in red text at the top of the tab, directly to the left of the CFSI logo.

Q16. Is a "non-CMRT" document acceptable?
A16. Suppliers are encouraged to review the Instructions tab of the CMRT. In short, the No, only the CMRT survey meeting the requirements is acceptable. See in Q10, Q11 and Q12. Do not send ROHS, REACH or Tax Forms as these do not apply to conflict minerals.

The results of the Checker are in two places on the CMRT:

Q17. If no 3TGs are used, is the supplier still required to complete the CMRT?
A17. Yes, this "no 3TG" information will be captured using the CMRT as well as ensure your status is defined as "responded" versus "no response". A response fulfills your obligation to customer as per PO Ts&Cs and 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 complete the Declaration.

Q18. Do Questions A through J need to be answered?
A18. Yes, if you provide materials to customer that contain the minerals. If you are declaring no 3TG: as per Q17 above, you do not need to answer these questions.

Q19. Where should the CMRT form be sent?
A19. All documents or communications should be sent back to the requesting email address conflictminerals@customer.sensitel.com.

Glossary Of Terms


Term What it means
3T&G,3Ts&G,3TG Tin,Tungsten,Tantalum & Gold(The Conflict Minerals)
CFSI Conflict Free Sourcing Initiative: joint initiative of the EICC (Electronic Industry Citizenship Coalition) & GeSI (Global e-Sustainability); the flagship organization behind the conflict minerals RCOI process and smelter audits
CFSP Conflict-Free Smelter Program: CFSI's smelter audit and certification program
CMRT Conflict Minerals Reporting Template: refers to the survey document, actually an Excel workbook, and the only acceptable response format
ConMIn Abbreviated term for "conflict minerals"
Covered Contries Inclusive terms for the countries covered under conflict minerals rule
DRC Democratic Republic of the Congo (the largest of the covered countries); also used to inclusively refer to the covered countries
RCOI Resonable Country Of Origin Inquiry; The CMRT is the survey RCOI document
SOR's Smelters Or Refiners

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