Building a Responsible Sourcing Program: Where to Start

Building a Responsible Sourcing Program: Where to Start

Mineral mining has been a key component of societal progress since the Industrial Age. However, in recent years, numerous reports of human rights violations have revealed the poor working conditions of some mines in conflict affected countries, such as the Democratic Republic of the Congo.

While laws have been put in place to mitigate the negative social impact of minerals like tantalum, tungsten, tin and gold (3TGs), activists, non-governmental organizations and consumers are insisting companies do more to drive corporate social responsibility (CSR) initiatives. In reaction to mounting pressure and evolving regulatory requirements, some companies are voluntarily collecting and reporting data on several minerals of concern used in the manufacture of their products, including cobalt, mica and lithium.

These companies are able to stay ahead of market expectations, demonstrate due diligence to conscientious clients and customers, identify supply chain risks and protect against the potential adverse effects of mineral sourcing activities. With all of these advantages, it is clear that companies should strive to build a responsible minerals program. The only question remaining is how to get started, and best practices for launching your CSR program are outlined below.

Find Out Who You Are Working With

First, carry out a scoping analysis to determine which of your components or products may contain minerals of concern. One way to accomplish this is by sending suppliers the applicable industry standard reporting template, either the Conflict Mineral Reporting Template or Cobalt Reporting Template.

Alternatively, companies can perform an engineering analysis, which involves commodity and procurement teams analyzing products to determine which contain minerals of concern. If there are hundreds or thousands of components to consider, it is preferable to start with an engineering analysis to reduce both the number of suppliers that need to be contacted and the amount of data that needs to be collected.

Develop a Process to Support Your Needs

Once you determine the scope of data you need to collect, the next step is establishing collection processes and designing an end-to-end responsible minerals plan to reflect your needs. Start by detailing production steps for each of your products and determining your company’s standards for each of those steps, with regulatory standards and customer expectations in mind. Your standards should include details on what is considered risk, how you will address risk issues and your expectations for third-party engagements (such as audits).

At the outset of this process, there will likely be many gaps, which you can fill by creating a list that includes suppliers to contact and the information you need to collect from each. Next, determine processes for supplier communication and monitoring as well as measuring data collection progress and reviewing achievements against your stated goals.


For a more detailed look at how to build a comprehensive responsible minerals program, download our guide.


Engage Your Suppliers 

Supplier engagement is imperative for any responsible minerals program. Without supplier participation, companies cannot obtain necessary materials source of origin information, as obtaining this information requires reaching out to suppliers to request support in gathering the names of smelters and refiners that provide materials.

You may regularly contact some suppliers to make orders, but sales contacts likely do not have the product data you’re looking for. However, they may be able to direct you to the correct contact. If not, you may be directed to the right person by making an inquiry through the contact page on your supplier’s website.

Once the correct contact has been found, inform them of an impending request so they have time to collect, organize and authorize the release of data. Be sure to provide suppliers with the correct format for submissions to ensure the data is compiled in a usable way.

When the full data request is sent, make it clear and detailed. Include the following:

  • A polite information request with logical reasoning.
  • A link to the form or survey they are required to complete.
  • A link to educational materials.
  • Clear instructions on how to correctly complete the request.
  • A point of contact for questions.
  • Links to key resources.

Manage Your Data

The volume of data coming from suppliers may seem overwhelming. To keep it organized, store data in a centralized location and maintain records of everything that is received to avoid contacting suppliers multiple times for information they have already provided. When sending requests to many suppliers, you’ll want an easily replicable process. One way to do this is to automate requests and follow-ups.

To ensure the efficiency of the process, analyze data as it is collected to ensure completeness and correctness rather than at the end. Companies need to verify suppliers have completely filled out the required details. They should include details about any minerals of concern contained in their products, the scope of the supply chain data collection process, their stance on issues related to mineral mining and their support for the investigation. They must also validate that the information provided is accurate. Because of the time-consuming nature of this process, the simplest approach to data analysis is with a data aggregator that displays all survey responses or questions at once.

Leverage a Software Solution

Given the volume of data most companies need to collect to demonstrate responsible mineral sourcing, maintaining a manual collection and tracking process can be extremely challenging. Assent’s software solution combines leading technology with unparalleled supply chain expertise to save time and money while protecting companies from the risks associated with regulatory violations.

Find out how Assent can help you take your responsible minerals program to the next level by contacting our supply chain experts at info@assentcompliance.com.

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