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Supplier- vs. Part-Centric Approaches to Comply With SEC Conflict Minerals Rule
Author: Lisa Reisman, MetalMiner , Published on: 29 January 2013
MetalMiner’s recently published...“The Definitive Guide to Conflict Minerals Compliance for Manufacturers.” ...Another question raised by the SEC rules involves the purchase of what we might deem “vanilla commodities,” such as steel HRC (hot rolled coil), from mills that also produce tinplate...Does an OEM buying vanilla HRC from a tinplate producer (e.g. US Steel, ArcelorMittal, Severstal...) need to verify that the steel producer is certified conflict-free, or can the OEM effectively ignore that part of the due diligence process since HRC doesn’t contain tin, tungsten, tantalum and gold...?...A supplier-centric approach to conflict minerals compliance involves the use of the sorts of sourcing surveys or tools we have described...that are provided to all or a portion of an OEM’s supply base.