On April 29, the Conflict Free Sourcing Initiative, CFSI, released the newest version (v. 4.10) of the Conflict Minerals Reporting Template, CMRT. This is the 14th new release, the fifth release at version 4, and the first update since CMRT v.4.01b, released on November 16, 2015.
Updates to CMRT v.4.10 include corrections to bugs and errors, updated smelter lists including the re-introduction of “smelter not yet identified” and automated population of columns B-J on the “Smelter List” tab, enhanced instructions and directions, ASCII character sett alignment, and language enhancements including the addition of Turkish.
The smelter list used in this version dates from March 23, 2016. As always, updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at www.conflictfreesourcing.org.
The new CMRT provides a unique opportunity for corporations and individuals collecting CMRT data as part of their due diligence surrounding a reasonable country of origin inquiry (RCOI) for SEC Reporting. Q Point adopts the stance that data provided from the latest version of the CMRT indicates updated information. That is to say, a CMRT v. 4.01a contains older, and perhaps out of date, information when compared to a current CMRT.
As a result of the value of current data and the release of the new CMRT, corporations and individuals may use the new CMRT as a mechanism for updated conflict minerals data and overall improved data collection from their suppliers. Alerting suppliers to the new CMRT can also lead to a discussion that sets expectations for an annual update and the use of the latest CMRT version. Exclusive use of the new CMRT will produce Form SD filings with the SEC that will show data received in the current year after April 29, 2016. This will demonstrate the necessary due diligence that is a component of the RCOI. Also, any effort in communicating requirement and expectations to a supplier can be similarly used in the Form SD.