The definition of conflict mineral in the legislation is:
CONFLICT MINERAL.-The term "conflict mineral'' means
(A) columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives; or
(B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.
In other words, it is not just where the mineral comes from that makes it a conflict mineral.
CDX Conflict Minerals Declaration Manager
Conflict Minerals in CDX
On July 15, 2010 the US Congress passed the Wall Street reform bill that included a provision on conflict minerals. The language in the bill requires companies that use tin, tungsten, tantalum, or gold in their products or production of their products and report to the US Securities and Exchange Commission to file an annual disclosure report with the Securities and Exchange Commission detailing whether these materials originated in the Congo or its adjoining countries. The bill requires companies to audit these reports to assure whether they are sourcing from conflict mines or not.
The first milestone for reporting to the SEC is May 31, 2014 for 2013. In future the companies need to provide their reports always on March 31 for the past calendar year.
Many companies are already cascading an information letter through the supply chain making suppliers aware of this new requirement. In the letter they ask suppliers to:
- Determine what components and products use conflict minerals or their derivatives.
- Work with suppliers to map supply chains of those components.
- Require suppliers to identify smelters used or verify that the origin of conflict minerals is scrap or recycled material.
Conflict Minerals Declaration Manager in CDX
Based on the Dodd-Frank Wall Street Reform and Consumer Protection Act requirements, the CDX Conflict Minerals Declaration (CMD) Manager assists in the declaration process and roll up of information received from supplier companies.
The CMD Manager within the CDX System helps to meet your reporting requirements and enables a managed Conflict Minerals Declaration process with full control over the company's supply chain and provides the best solution to manage the CMDs of business partners both working in CDX and exchanging CMDs with business partners not being registered in CDX.
The CDX CMD Manager provides different options for the management of CMDs:
- Import of CMDs in an Excel format as defined by one of the different EICC-GeSI template versions from suppliers which are not registered in CDX.
- Creation, sending and receiving of CMDs of and to companies registered in CDX.
- Incorporate CMDs received either via import or from CDX-using suppliers into your own company's CMDs.
- Export of CMDs into Excel files based on one of the template versions as defined by the EICC-GeSI.
- Sorting and grouping of smelters within a CMD to provide an optimized view of the smelters, especially in complex declarations.
- Validation and plausibility checks of CMDs imported into or created in CDX.
The CDX CMD Manager handles different kind of smelters:
- Standard smelters which are listed in a version of the EICC-GeSI template
- EICC-GeSI Conflict Free Smelters
- Smelters which register themselves in CDX
- Alleged smelters defined by the creator of a CMD
- Distributors and other facilities commonly yet incorrectly reported as smelters.
The CDX CMD Manager provides the best solution to manage the CMDs of business partners; both those working in CDX and not being registered in CDX.