Part Level Conflict Mineral Compliance in 2015

Part Level Conflict Minerals Compliance
2015

Table of Contents
INFO@ASSENTCOMPLIANCE.COM | WWW.ASSENTCOMPLIANCE.COM | TEL: 1-866-964-6931
1. Why you need to Graduate to the Parts/Product Level
2. Getting Internal Product/Part Level info
3. Requesting data from Suppliers
4. Data Verification
5. Product Level Reporting for Customers and the SEC
6. How do I get there ASAP?
7. Q&A

Why you need to Graduate to the Product Level
Product Level reporting
In order to report to your customers and the SEC at the Product Level, you need to make
requests at the Part level
Differentiate between customer requests
Fewer customers are starting to accept Company level declarations
This will continue to decline in 2015 – rapidly
Get better info from your suppliers
More precise responses which pertain to your specific products (as opposed to Corporate level
declarations which mix in all your suppliers info along with all their customer’s info)
This is especially true with your larger Suppliers
Accurate Smelter list
Right now, if you are not at the Product Level – your smelter list is 25-50% inaccurate
(depending on your size and industry).
This means you are reporting inaccurate info to the SEC
You need to focus on your products, just like your customer needs to focus on theirs.

Getting Internal Product/Part info
Getting BOMs
Review: Sample Supplier List vs. BOM
Transferring from a simple supplier list to product BOMs is this is the biggest stumbling block and
speaks to scalability
Part level inquiry and Data Management can not be done manually
Need some sort of IT system
Internally or Externally – you will need some help
25% of new clients come to us with a 3rd party system in place that can't handle BOMs properly
This is a common problem
There are strategies that can be employed but you need to identify your requirments to IT – they will
not solve this puzzle for you
Assent Switch program enables you to Graduate from a Supplier approach to a Product level
approach

Requesting Data from Suppliers
You must control the parts list
Provide your suppliers with part numbers or 1 of the following 2 things will occur:
They’ll ask for the list anyways
In this case, you need to go get a parts list anyways
They’ll give you their parts list on the Product List tab
In this case, you will need to cross-reference the data they input on the Product
List tab against the data in your database
This will involve matching Supplier Part numbers against your database
All routes point to you being able to produce a parts list with Supplier Part numbers
Best Practices
Provide a list upfront with your request
Have a Supplier parts list ready in either of the following formats
Downloadable Attachment (Ex: Excel)
Remember to use their part numbers if possible!
This can be quite cumbersome/impossible to do manually
If using a portal, display the info on the portal
Have Suppliers declare against the list
Need a mechanism for questions/disputes regarding part numbers

Data Verification
Sanity check the data received versus part descriptions and material types
We still see people interpreting "No Conflict Minerals" as 3TGs from Conflict Free sources
(Question #3)
Start feeding data received into part level information
Roll this up to products
Enables product level and Customer Specific CMRTs
Enables the required specificity in your Conflict Minerals Reports
Check your product roll-ups
Review Key Accounts
Review Key Product Categories
Focus your due diligence accordingly
Fix the problem Suppliers who have the biggest impact by Customer and Product Category
This is now part of your process and speaks to the overall strength of your program and
validity of your data

Reporting Data
Product level CMRTs
Roll-up of Part level information that is specific to Products or Product categories (depending
on the way you have setup your BOM info)
Customer level CMRTs
Roll-up of Product level CMRTs for a specific customer
Addresses all product purchased by your customer
Narrows your Smelter list (and Risk)
Conflict Minerals Report
Disclosure of Smelters and Refiners is now more accurate (since the list is reduced and only
pertinent to your products)
Country of Origin is more accurate
Part of Best Practices for Next Steps 2015/2016 in order to advance your program

How do I get there ASAP?
1. Take a flat BOM (don't start with your Supplier list)
2. For every item (not Product) - match it to a Vendor number
3. Send that to your friendly Service Provider - 
4. Get your legacy data pulled in
5. You are now ready to graduate to the Parts Level

2015 – What’s next
Give us CMRTs you have received from your Supply Chain and will run a Red Flag analysis & Data
Validation check on them at no cost!
Slide deck and Recording to be sent shortly
Continued Tactical level Webinar Series
The webinar series continues next week - January 29th
Top 3 problems with Smelter Verification and how to solve them
Register here: https://attendee.gotowebinar.com/register/6845150738968533762
The rest of the series can be found here: http://www.assentcompliance.com/webinar.asp

Questions
?

Part Level Conflict Mineral Compliance in 2015

Recommended

Recommended

More Related Content

More from Matt Whitteker

More from Matt Whitteker (20)

Recently uploaded

Recently uploaded (20)

Part Level Conflict Mineral Compliance in 2015