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    Cost-effective Conflict Mineral Compliance

    Conflict Minerals Compliance, popularly known as 3TG Compliance, has become a major challenge for companies who are SEC listed. Submitting Form SD is mandatory for SEC-listed companies. The process of compliance requires a lot of effort to complete the Reasonable Country of Origin Inquiry (RCOI) and implement the due diligence mechanism within the company.

    Sunstream has a great track record of providing conflict mineral compliance. We will take up the responsibility of collecting the CMRT (Conflict Minerals Reporting Template) from your suppliers. Our team will also validate the smelter data and ensure that it is reported with 100% transparency and accuracy.

    Our consultants have helped companies with Conflict Minerals Compliance and have enough knowledge and expertise to help you tide over the compliance process smoothly.

    Our conflict minerals services support

    • Compliance consulting.
    • Due diligence implementation.
    • RCOI support and CMRT (Conflict Minerals Reporting Template) collection.
    • Supplier Training.
    • Smelter Red flag identification & resolution.
    • Selection & implementation of conflict minerals tool.
    • Meet the requirements Of US SEC filing With Our conflict mineral compliance reporting.

    How Sunstream helps you with Conflict Mineral Compliance? 

    Conflict minerals include Tin, Tantalum, Tungsten and Gold popularly known as 3TG. Companies who use these metals produced in DRC (Democratic Republic of Congo) or elsewhere need to declare it in their annual statement to SEC.

    There are three steps in this conflict mineral compliance procedure. The first two stages will influence the need for the final step. In most cases, companies would need the support of their suppliers in order to gain the information required to satisfy the obligations under this regulation. It can drastically slow down the Conflict Minerals Compliance process. 

    Time and resources in a company are very crucial in determining its success. Therefore, Sunstream helps an organization with compliance in a timely manner. We have earned a lot of experience by working with many clients across industries. It has equipped our consultants with all the experience needed to provide accurate and reliable services in Conflict minerals, REACH, and RoHS Compliance. We will make the process simple and save a lot of time and resources for our clients.

    Which companies will be covered under this regulation?

    The conflict minerals supply chain involves a lot of players who participate in the supply chain of the material from a raw form to a finished product. Those who extract minerals from the site and process them become the upstream companies.  On the other hand, the companies that further refine the materials into a finished product and deliver it to the final consumer are the downstream companies.

    Conflict mineral compliance will apply to all companies those file a report to US SEC under Sections 13(a) and 15(d) of the Exchange Act. Companies which are not mandated to file a report to SEC will also get affected if any of their customers in their supply chain is affected by the law and need information from them to file the report.

    The framework of the Compliance procedure 

    Are the company’s products covered in the act?

    Conflict Minerals Compliance starts by assessing whether the company’s products and activities come within the purview of this regulation. Our consultants will start observing the products manufactured or bought by the company that have any one of the conflict materials. If a product within the scope of the law is found, then we will inquire whether it is vital for the functioning or the production of the product. In case it is not, then the company would not be obliged to file Form SD or perform additional procedures under this regulation.

    Reasonable Country of Origin 

    The next step would be to ascertain if the minerals came from the DRC or any other covered countries. In this step, our consultants will help you prepare all the documentation and filings as required in the Conflict Minerals Compliance

    Exercising Due Diligence and Conflict Mineral Reporting 

    Sunstream will help you with implementing due diligence on the origin and chain of custody pertaining to Conflict minerals. Our experts will sort out all the procedures and render transparent services to our clients. 

    We specialize in making Conflict Minerals, RoHS, REACH, and SDS services effortless for you. The entire process will be performed with keen attention to detail and our consultants will ensure that you face the least inconvenience while complying with all the norms. 

    Consult our experts today!

    Frequently Asked Questions on Conflict Minerals

    Conflict minerals are defined by the US law which includes Tin, Tantalum, Tungsten and Gold (3TG) that are extracted from minerals cassiterite, columbite-tantalite and wolframite, respectively. These conflict minerals are natural resources that are mined often from war-torn regions (conflict areas), which is often utilized to support the armed conflict financially and human right abuses. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, which is internationally recognized, has a wider scope of minerals other than 3TG.

    The conflict minerals are extracted from various parts of the world including the Democratic Republic of Congo (DRC)  Apart from DRC, Afghanistan, Colombia, Zimbabwe and Myanmar are also known for producing conflict minerals.

    As per SEC rule, the 3TG minerals that are extracted despite the region are called conflict minerals. However, at the same time SEC also defines “DRC conflict-free” for the minerals that are extracted but does not support the armed conflict directly or indirectly. For instance, if Tin extracted from Canada, Argentina, or Russia are called Conflict Minerals, but Tin extracted from Canada does not support the armed group, then they are called “DRC conflict-free”.

    In 2010, the U.S. Congress passed Section 1502 of the Dodd Frank Act to check their supply chains for tin, tungsten, tantalum and gold. 

    Currently, Responsible Minerals Initiative (RMI) is an organization which has come up with a process for companies and their suppliers to manage their conflict mineral due diligence process. US companies can adapt to the process established by RMI to ensure that they are not supporting conflict minerals.

    Sunstream has expertise in consulting and providing services to assist companies to adopt Conflict mineral compliance processes as laid out by RMI. Sunstream can provide a complete solution for the conflict mineral compliance process. 

    Sunstream can provide services including consulting services, due diligence implementation, reasonable country of origin inquiry support, supplier training and data management.

    At Suntream we have a large customer base right from the electronics and electrical industry, ensuring their compliance with the regulation through conflict mineral services. 

    Sunstream has been able to manage the compliance end to end for our customers and deliver an average cost saving of 40%.

    Sunstream can streamline the preparation of the Conflict Minerals Report (CMR) by offering a comprehensive suite of services, including data collection, analysis, consolidation, and reporting  from your suppliers. Our team will also validate the smelter data and ensure that it is reported with 100% transparency and accuracy.

    Sunstream employs advanced supply chain mapping tools and proprietary databases to identify smelters and refiners in your supply chain. We cross-reference supplier data with industry-verified smelter and refiner lists, such as those provided by the Responsible Minerals Initiative (RMI).

    The timeline for implementing conflict minerals compliance measures typically spans 3 to 12 months, depending on the complexity of the supply chain.

    Sunstream specializes in supply chain mapping by utilizing advanced software and services  to trace the flow of materials from raw material sources to end products. We integrate supplier engagement platforms to collect accurate data and analyze supplier relationships.

    Sunstream employs several methods to ensure transparency, including:

    • Due diligence implementation.
    • Compliance consulting.
    • RCOI support and CMRT (Conflict Minerals Reporting Template) collection.
    • Smelter Red flag identification & resolution.
    • Supplier Training.
    • Selection & implementation of conflict minerals tool.
    • Meet the requirements Of US SEC filing.

    Sunstream facilitates supplier communication through automated platforms and services by our experienced compliance team that send surveys, reminders, and updates. Our services  support the Responsible Minerals Initiative (RMI) Conflict Minerals Reporting Template (CMRT) for standardized data collection. Sunstream also offers multilingual support and conducts training sessions to help suppliers understand compliance requirements, ensuring accurate and complete data submissions.

    Yes, Sunstream assists organizations in obtaining certifications such as the Responsible Minerals Assurance Process (RMAP). We provide guidance on meeting certification criteria, conducting due diligence audits, and preparing the necessary documentation.

    Sunstream offers tailored supplier training and compliance consulting to empower companies and their suppliers to achieve and maintain compliance effectively.

    Sunstream can support several other compliance initiatives of metals and minerals. Talk to us today to understand how we can support the specific initiatives.