BQCIS

Ensuring Responsible Sourcing of 3TG Minerals

Global regulations such as the US Dodd-Frank Act §1502 and the EU Conflict Minerals Regulation require companies to perform due diligence on their supply chains for tin, tantalum, tungsten, and gold (3TG) to confirm that these minerals are not sourced from conflict-affected or high-risk areas (CAHRAs).

Compliance requires implementing clear sourcing policies, supplier surveys using the Conflict Minerals Reporting Template (CMRT), identifying and validating smelters or refiners via programs like the Responsible Minerals Initiative (RMI), and publishing transparent annual reports following the OECD Due Diligence Guidance.

BQCIS supports organizations with independent due diligence audits, smelter conformance verification, supplier declaration reviews, and compliance gap assessments—helping ensure that public filings and disclosures are evidence-based, credible, and regulator-ready.

Key Compliance Activities

Due Diligence Process Audit

Evaluating company policies, supplier CMRT data collection, risk-assessment processes, and disclosure practices against OECD Guidance requirements.

Smelter / Refiner Conformance Verification

Auditing smelters or refiners under global assurance programs (e.g., RMI RMAP, LBMA Responsible Gold) to verify conflict-free sourcing systems.

Key Benefits of Conflict Minerals Compliance

Regulatory Compliance

Meet Regulatory Obligations

Ensures conformance with Dodd-Frank 1502 and EU Conflict Minerals reporting mandates through auditable due diligence documentation.

Responsible Sourcing

Demonstrate Responsible Sourcing

Builds stakeholder trust by evidencing ethical sourcing and avoiding contribution to conflict financing.

Transparency

Increase Supply-Chain Transparency

Provides visibility down to smelter / refiner level, enabling data-driven sourcing decisions and partner accountability.

Risk Management

Manage Reputational & Investor Risk

Protects your brand and investor confidence by ensuring alignment with ESG expectations and human-rights principles.

Success Story

Independent Audit Supports Accurate SEC Filing

The Challenge:

A US-listed electronics manufacturer required an independent review of its 3TG due-diligence system to support its annual SEC Conflict Minerals Report.

Our Solution:

BQCIS reviewed supplier CMRT data, smelter lists, and RMAP alignment, identifying documentation gaps and enhancement areas for OECD conformance.

The Result:

The audit validated the company’s due-diligence framework, enabling a fully compliant SEC filing and reinforcing its reputation for responsible mineral sourcing.

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