Conflict-Free Smelter Program
The CFS is a voluntary program in which an independent third party evaluates a smelter’s procurement activities and determines if the smelter demonstrated that all the materials they processed originated from conflict-free sources. The program aims to enable companies to source conflict-free minerals. Companies that want to source responsibly will be able to use the results of the audits for their own company’s due diligence program.
The CFS assessments cover smelters processing tin, tungsten, tantalum, and refiners processing gold (called smelters here forward). The assessments are conducted globally for any smelter who is processing the targeted minerals and wants to be identified as a conflict-free smelter. Key processors are located in China, Malaysia, Russia, United States, and Indonesia.
The CFS Program consists of two reviews that occur at a smelter’s site:
Business Process Review:
- Evaluate company policies and or codes of conduct relating to conflict minerals
Material Analysis Review:
- Conduct a complete chain of custody analysis to demonstrate that sources of all materials procured by the smelting company, appropriate to the audit period, are conflict-free
- Evaluate whether source locations are consistent with known mining locations
- Establish whether material identified as “recycled/scrap” meets the definition of recycled/scrap material
If, during the assessment, the smelter is able to demonstrate that they have sourced conflict-free, based on the sourcing location requirements of the CFS program, the third party assessment firm will recommend to the CFS Assessment Review Committee that the smelter be identified as being compliant. The CFS Committee reviews the assessment report, and if they agree that the Assessor’s conclusions, they will recognize the smelter as being CFS-compliant.
If, during the assessment, the third party assessment firm finds non-compliances to the CFS protocol, the smelter will have three months to resolve the issues and undergo a reassessment.
The EICC and GeSI publish lists of smelters, by metal, found to be compliant with the CFS protocol; the lists will be updated quarterly, or more frequently if appropriate. The EICC and GeSI will not publish information on smelters who are either not compliant with the CFS protocol or have not gone through a CFS assessment. Inquiries as to a smelter’s CFS status should be made directly with the smelter in question. Registration is required to access the CFS smelter list.
Determination of whether and/or how to use all or any portion of the list is to be made in a company’s sole and absolute discretion. Use of the list is voluntary; the EICC and GeSI do not require members or their supply chains to purchase from the compliant smelter list.
Based on the Dec. 2010 proposed rule of the U.S. Securities and Exchange Commission (SEC) to implement the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 (“Dodd-Frank”) provisions on conflict minerals.
(Last updated December 11, 2012)
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