On April 27, the Responsible Minerals Initiative, RMI, released the newest version (v. 5.11) of the Conflict Minerals Reporting Template, CMRT. This is the 19th version, the fourth release at version 5, and the first update since CMRT v. 5.10, released on December 1, 2017.
The major updates to this version of the CMRT are the correction of bugs and errors, enhancements that do not conflict with IPC 1755, updates to the ISO short names for countries, states, and provinces, and regular maintenance updates to the smelter lists.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.responsiblemineralsinitiative.org. The next update to the CMRT is anticipated for November 2018.
The new CMRT provides an 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 That is to say, a CMRT v. 5.01 contains potentially out-of-date information when compared to a current CMRT (v. 5.11).
Corporations and individuals may use the new CMRT as a mechanism for gathering updated conflict minerals data and improving overall data collection from their suppliers. Alerting suppliers to the new CMRT may lead to a discussion that sets expectations for routine updates 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 27, 2018. This will demonstrate the necessary due diligence that is a hallmark of reasonable country of origin inquiry (RCOI). Also, any effort in communicating a requirement and expectations to a supplier can be similarly used in the Form SD.
The RMI has also released a pilot program for the collection of data pertaining to Cobalt. A follow-up article will focus specifically on this new effort and its implications.