Conflict Minerals. Overview and Expectations

Transcription

1 Conflict Minerals Overview and Expectations

2 What are Conflict Minerals? Dodd-Frank Wall Street Reform and Consumer Protection Act Section 502 Conflict minerals are minerals mined in conditions of armed conflict and human rights abuses Coltan Tantalum These are the four conflict minerals (3TG): Casserite Tin Wolframite Tungsten Gold Adient / Conflict Minerals Overview and Expectations 2

3 Conflict Minerals Covered Countries The Democratic Republic of the Congo and adjoining countries Adient / Conflict Minerals Overview and Expectations 3

4 Conflict minerals Usage in the Automotive Industry Picture source: AIAG report, May 2011 Adient / Conflict Minerals Overview and Expectations 4

5 Conflict minerals Usage in the Automotive Industry Picture source: AIAG report, May 2011 Adient / Conflict Minerals Overview and Expectations 5

6 Conflict Minerals Reporting Why? > Reporting obligation (part of the financial reporting to SEC) due May, 31st each year How? > Following the OECD Due Diligence Guidance: > Identify suppliers > Receive declarations > Perform plausibility checks > Roll up final report and send to customer What? > Information on the company policy on Conflict Minerals > List of identified smelters from the complete supply chain Adient / Conflict Minerals Overview and Expectations 6

7 Conflict Minerals: Timeline When? Possible status for a company: Not CM free Indeterminate CM conflict free CM free Sources for Conflict Minerals not yet fully known Some or all products contain 3TGs sourced from the DRC*, NOT from a conflict free smelter 3TGs are sourced from the DRC*, but from a conflict free smelter 3TGs for all products are NOT sourced in the DRC* *DRC: Democratic Rebublic of the Congo Adient / Conflict Minerals Overview and Expectations 7

8 Conflict Minerals Reporting in Adient To fulfill our requirements on conflict minerals reporting the following steps are needed: > Register for the IPCMP platform. This is mandatory. The Basic Licence is free of charge > Respond to our Initial Supplier letter within 30 days providing us with your IPCMP ID and the name and contact details of your CM contact > Collect smelter information from your suppliers. Please use either IPCMP (recommended) or the CFSI template (link to the CFSI page) > Use available IMDS data, the AIAG guideline and the AIAG decision tree to verify incoming data from your supply chain > Submit your declaration to Adient. Include your vendor number and your IMDS company ID* to the company ID field of the CMRT * Only IMDS reporting companies Adient / Conflict Minerals Overview and Expectations 8

9 Conflict Minerals Reporting in Adient Your tasks: > Collect the Conflict Minerals data from your supply chain during the reporting year > Submit your declaration until deadline > Review and update your declaration thoughout the year > Resubmit your final declaration until December 31, 2016 > We will reject your submission when the reporting template is older than version 4.10 incomplete and incorrect data are identified in the declaration the 3TG declaration does not correspond to available material or component information Adient / Conflict Minerals Overview and Expectations 9

10 Appendix Adient / Conflict Minerals Overview and Expectations 10

11 Conflict Minerals: IT-Solution IPCMP by ipoint Create reports Import reports Aggregate (roll-up) reports Perform validation Checks All data in one place Sophisticated folder structure Due diligence reporting Manage & respond to requests from your customers Send & manage requests to your suppliers Statistics of accepted reports Adient / Conflict Minerals Overview and Expectations 11

12 Select Language Preference Here: 请选择你的语言 : 사용할언어를선택하시오 : 表示言語をここから選択してください : Sélectionner la langue préférée ici: Selecione Preferência de idioma Aqui: Wählen sie hier die Sprache: Seleccione el lenguaje de preferencia aqui: Selezionare la lingua di preferenza qui: Burada Dil Tercihini Belirleyin: English Answer the Following Questions at a Company Level 2016 Conflict-Free Sourcing Initiative. All rights reserved. Revision 4.10 April 29, 2016 Link to Terms & Conditions Conflict Minerals: Reporting Format > The officially supported reporting format by AIAG > The template is available in 9 languages already > The latest version can be found here > It contains seven questions on the use of tin, tantalum, tungsten and gold and the reporting status > Ten questions are dealing with the overall company policy on Conflict Minerals The purpose of this document is to collect sourcing information on tin, tantalum, tungsten and gold used in products Mandatory fields are noted with an asterisk (*). Company Information Company Name (*): Declaration Scope or Class (*): Description of Scope: Company Unique ID: Company Unique ID Authority: Address: Contact Name (*): Contact (*): Phone Contact (*): Authorizer (*): Title - Authorizer: - Authorizer (*): Phone - Authorizer (*): Effective Date (*): Answer the following questions 1-7 based on the declaration scope indicated above 1) Is the 3TG intentionally added to your product? (*) Answer 2) Is the 3TG necessary to the production of your company s products and contained in the finished product that your company manufactures or contracts to manufacture? (*) Answer 3) Do any of the smelters in your supply chain source the 3TG from the covered countries? (SEC term, see definitions tab) (*) Answer 4) Does 100 percent of the 3TG (necessary to the functionality or production of your products) originate from recycled or scrap sources? (*) Answer 5) Have you received data/information for each 3TG from all relevant suppliers? (*) Answer Conflict Minerals Reporting Template (CMRT) 6) Have you identified all of the smelters supplying the 3TG to your supply chain? (*) Answer 7) Has all applicable smelter information received by your company been reported in this declaration? (*) Answer Question Answer A. Do you have a policy in place that addresses conflict minerals sourcing? (*) B. Is your conflict minerals sourcing policy publicly available on your website? (Note If yes, the user shall specify the URL in the comment field.) (*) C. Do you require your direct suppliers to be DRC conflict-free? (*) D. Do you require your direct suppliers to source the 3TG from smelters whose due diligence practices have been validated by an independent third party audit program? (*) E. Have you implemented due diligence measures for conflict-free sourcing? (*) F. Do you collect conflict minerals due diligence information from your suppliers which is in conformance with the IPC-1755 Conflict Minerals Data Exchange standard [e.g., the CFSI Conflict Minerals Reporting Template]? (*) G. Do you request smelter names from your suppliers? (*) H. Do you review due diligence information received from your suppliers against your company s expectations? (*) I. Does your review process include corrective action management? (*) J. Are you subject to the SEC Conflict Minerals rule? (*) Adient / Conflict Minerals Overview and Expectations 12