Conflict Mineral Compliance (CMRT) at ChemTecUSA
ChemTecUSA’s supply chain management includes a formal conflict mineral policy. This policy directs our approach to materials containing tin, tantalum, tungsten and gold (3TG). Our use of the Conflict Minerals Reporting Template (CMRT) and the resulting report are practical applications of this policy. This page provides a clear account of our process and its output.
Our Conflict Mineral Policy
Our conflict mineral policy is an internal operating rule. It states that ChemTecUSA will make a reasonable effort to determine the source of 3TG minerals in the products we manufacture and sell. The policy prohibits the knowing use of 3TG minerals that directly finance armed groups in the Democratic Republic of the Congo (DRC) and adjoining countries. This policy is distributed to our procurement team and is a required part of our supplier agreements.
The CMRT
To enact our policy, we rely on the Conflict Minerals Reporting Template. The CMRT is a form developed by the Responsible Minerals Initiative (RMI). It functions as a common language for supply chain inquiries. We send the CMRT to suppliers of components and raw materials that are likely to contain 3TG minerals. The template asks suppliers to list the smelters and refiners in their supply chains for these materials. This data gives us a view into the origins of the minerals we use.
Our CMRT Reporting Process
Our CMRT reporting is the result of a methodical data collection and review cycle. This process occurs annually and follows a set pattern.
- Scoping and Identification: We examine our bill of materials for each product line. We determine which items and suppliers fall under the scope of relevant regulations, such as the U.S. Dodd-Frank Act Section 1502. These suppliers receive a formal request for a completed CMRT.
- Data Gathering and Validation: Received CMRTs are checked for completeness. Our staff verifies that all required fields are filled. We then cross-reference the listed smelters and refiners against the RMI’s published list of facilities that have passed an independent audit. This audit confirms a smelter’s sourcing practices. We contact suppliers to clarify incomplete responses or to request corrections.
- Compilation and Analysis: Data from all suppliers is combined. We calculate the percentage of 3TG in our products that can be traced to these audited, conformant smelters. This analysis shows the depth of visibility we have achieved into our supply chain for the reporting period.
- Filing and Reporting: The final step is producing our company-level CMRT report. This document summarizes our findings and declares our due diligence measures. It is filed according to legal requirements and serves as our compliance disclosure. This report is our formal answer to inquiries about conflict minerals in our products.
What Our CMRT Reporting Provides to Partners
ChemTecUSA’s CMRT reporting is more than a compliance document. It delivers functional value.
- Supply Chain Transparency: The CMRT report offers a documented chain of custody for 3TG minerals. It gives our customers verified information about the materials in the products they purchase from us.
- Reduced Due Diligence Burden: By managing this process for our supply tier, we provide ready-made data to our customers. This supports their own reporting obligations and reduces the investigative work they must perform.
- Evidence of Policy Adherence: The CMRT report is direct proof that we follow our stated conflict mineral policy. It shows we take concrete steps to address sourcing risks.
Ongoing Management of the Program
Our conflict mineral program is active throughout the year. We integrate new suppliers into the CMRT request cycle as they are onboarded. We track changes to the RMI smelter lists and update our records. Training for relevant staff covers how to read a CMRT and how to validate the information it contains. This continuous effort maintains the integrity of our annual reporting.
Requesting Documentation
ChemTecUSA’s most recent CMRT filing and a statement of our conflict mineral policy are available for viewing. Customers and partners with specific questions about a product line or requiring documentation for audit purposes should direct their inquiry to our Compliance Office. We will provide the necessary materials to demonstrate our compliance status.