Section 1502 of the Dodd Frank Act requires all publicly traded companies to perform a yearly Reasonable Country of Origin Inquiry (RCOI) on the sources of 3TG (Tantalum, Tin, Tungsten and Gold) in their products and conduct due diligence on these metals to identify any sourced from the DRC and surrounding regions.
Companies must collect Conflict Minerals information from suppliers and identify parts containing 3TG. Supplier CMRT declarations and smelter lists must be compared to the CFSI approved list to identify smelters which are not yet certified conflict-free, and therefore could be sourcing from the region.
Bills of Materials (BOMs) evaluation: normalize part numbers to identify BOM and where-used impact for reportable or restricted materials. Acquisitions and mergers monitored
Suppliers are contacted to collect the most recent CMRT and supporting documentation. If assistance is needed, TPP will provide supplier training to ensure CMRT reports are correct and returned without unnecessary delays.
Suppliers’ CMRTs and smelter lists are reviewed for completeness and quality. Reported smelters are validated against the CFSI approved smelter list. TPP follows up with suppliers as part of the quality assurance process to ensure any corrective actions are addressed.
CMRT information is aggregated into organized reports for users to perform the required RCOI, generate CMRT reports, and initiate a due diligence investigation to complete the SEC’s Form SD. Supplier documents are maintained for compliance traceability and audit support.