SHEQ managers in the electronics industry will be used to dealing with requests from US customers regarding Conflict Minerals. Many SHEQ managers will include conflict mineral policies within their portfolio of compliance policies in their ISO 9001 documentation. Some customers may even require further analysis or assurance from a SHEQ manager regarding the 2nd or 3rd tiers in the supply chain, or details of minerals processors if they are part of your supply chain. In 2021, new legislation in the EU will mirror that of the US, so these requests on supply chain organisations will become more common.
Conflict Mineral legislation will definitely be applicable to your organisation if you are involved in exporting, importing or dealing with precious minerals or mineral-related products, your quality management system should reflect the requirements of international regulations and legislation. There are a multitude of international rules and regulations that have been imposed to try and limit the trade of conflict minerals – the proceeds of which finance civil conflict, resulting in human rights abuses. Businesses may inadvertently be in breach of legislation if they are unknowingly dealing in conflict minerals or products made with conflict minerals, resulting in a contaminated supply chain.
To protect these business operators from legislation breaches and potential civil penalties, a multitude of guidelines have been put in place. In a quality management system, managers should identify issues that affect the context of the organisation. Export, import and supply chain activities will definitely affect the context. Therefore, SHEQ managers should have processes in an ISO 9001 system that recognize international guidelines, the impact these can have and how to be compliant. Managers should ensure that they identify legislation for ISO 9001 procedures and regularly carry out compliance audits as part of their ISO 9001 audit programme.
Management, governance and regulations are almost exclusively focused on the procurement and production of four main minerals, also known as 3TG (Tin, Tantalum, Tungsten and Gold), that are found in almost exclusive abundence in Central Africa:
|Cassiterite||Ore from which tin is extracted.||Electric circuits and electronic components for various products.|
|Columbite-tantalite (Coltan)||Ore from which tantalum is extracted.||Electronic components for various products.|
|Wolframite||Ore from which tungsten is extracted.||Electronic components for various products. Numerous applications in aerospace, aeronautical and communications technology.|
|Gold||Rare metal known for numerous industrial applications and circulation on international markets.||Jewellery, electronic, mechanical and aeronautical applications.|
Conflict minerals can be categorised as minerals and other precious resources that are mined in conditions of armed conflict, usually civil wars, and human rights abuses and are sold or traded by armed militia groups and warlords, the proceeds of which are used for weapons procurements to further the scale of the conflict in question. For many years this has been a problem in countries such as Sierra Leone, Central African Republic, Liberia and the Democratic Republic of Congo. The resource endowment and mineral wealth of these countries are enormous. The DRC alone contains an estimated 65-80% of the world’s columbite-tantalite (coltan) reserves, 49% of its cobalt reserves, 25% of its industrial diamond reserves and 3% of its copper reserves. In short, the money-generating opportunities from these resources are significant, but the resulting human suffering it perpetuates is immense. Numerous non-state armed groups, including, but not limited to, the Democratic Forces for the Liberation of Rwanda (FDLR), rogue elements of DRC armed forces (FARDC) and the NDC-Rénové, are reportedly involved in the production and trade of these resources.
Furthermore, the distribution of supply isn’t uniform. While these armed groups control many independent mines in different areas there are also several major mining corporations working in and around these countries. In addition, a large proportion of supply comes from subsistence miners, also known as ‘artisanal’ miners. These miners are small-scale and independent from large domestic and international mining corporations, and make up 80-90% of all mineral production in the DRC alone. The problem is this supply stream becoming saturated with conflict minerals in the process of moving them to third party distributors overseas.
Companies can, intentionally or unintentionally, be affected by the risk of supply chain contamination with conflict minerals. This can occur at a number of stages of production, supply and procurement, either through direct mining or trading within the affected countries or further along the supply chain. If your business has been dealing in conflict minerals, it has been inadvertently been contributing towards the conflict in those countries, since the proceeds of conflict minerals are used for the continuation of armed conflict. As a result coming from supporting these armed groups, your business may be perpetuating violence against the civilian population and human rights abuses.
Published on 18 August 2020
Video Credit: "Conflict Minerals Do you know what's in your supply chain?" - Source Intelligence | Disclaimer: Spedan Ltd has reviewed this content and deemed it applicable to the topic but has not been associated in its production or publishing.
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