Conflict Minerals
Overview and Expectations
Adient / Conflict Minerals – Overview and Expectations 2
What are “Conflict Minerals”?
ColtanTantalum
CasseriteTin
WolframiteTungsten Gold
Dodd-Frank Wall Street Reform and Consumer Protection Act – Section 502
“Conflict minerals are minerals mined in conditions of armed conflict and human
rights abuses…”
These are the four conflict minerals (3TG):
The Democratic Republic of the Congo and adjoining countries
Adient / Conflict Minerals – Overview and Expectations 3
Conflict Minerals – Covered Countries
Adient / Conflict Minerals – Overview and Expectations 4
Conflict minerals –Usage in the Automotive Industry
Picture source: AIAG report, May 2011
Adient / Conflict Minerals – Overview and Expectations 5
Conflict minerals –Usage in the Automotive Industry
Picture source: AIAG report, May 2011
Why?
Adient / Conflict Minerals – Overview and Expectations 6
Conflict Minerals Reporting
> Reporting obligation (part of the financial reporting to SEC) due May, 31st each year
How?> Following the OECD Due Diligence Guidance:
> Identify suppliers> Receive declarations> Perform plausibility checks> Roll up final report and send to customer
What?> Information on the company policy on Conflict Minerals> List of identified smelters from the complete supply chain
Adient / Conflict Minerals – Overview and Expectations 7
Conflict Minerals: Timeline
When?
Possible status for a company:Not CM freeIndeterminate CM conflict free
3TGs are sourced from the DRC*, but from a
conflict free smelter
Some or all products contain 3TGs
sourced from the DRC*, NOT from a
conflict free smelter
Sources for Conflict Minerals
not yet fully known
CM free3TGs for all products are
NOT sourced in the DRC*
*DRC: Democratic Rebublic of the Congo
To fulfill our requirements on conflict minerals reporting the following steps are needed:> Register for the IPCMP platform. This is mandatory. The Basic Licence is free of charge> Respond to our Initial Supplier letter within 30 days providing us with your IPCMP ID and the name and
contact details of your CM contact> Collect smelter information from your suppliers. Please use either IPCMP (recommended) or the CFSI
template (link to the CFSI page)> Use available IMDS data, the AIAG guideline and the AIAG decision tree to verify incoming data from your
supply chain> Submit your declaration to Adient. Include your vendor number and your IMDS company ID* to the
company ID field of the CMRT
Adient / Conflict Minerals – Overview and Expectations 8
Conflict Minerals Reporting in Adient
* Only IMDS reporting companies
Adient / Conflict Minerals – Overview and Expectations 9
Conflict Minerals Reporting in Adient
Your tasks: > Collect the Conflict Minerals data from your supply chain during the
reporting year> Submit your declaration until deadline> Review and update your declaration thoughout the year> Resubmit your final declaration until December 31, 2016
> We will reject your submission when‒ the reporting template is older than version 4.10‒ incomplete and incorrect data are identified in the declaration‒ the 3TG declaration does not correspond to available material or component information
Adient / Conflict Minerals – Overview and Expectations 10
Appendix
Adient / Conflict Minerals – Overview and Expectations 11
Conflict Minerals: IT-Solution IPCMP by iPoint
Manage & respondto requests fromyour customers
Send & manage requests to your suppliers
Statistics of accepted reports
All data in one place Sophisticated folder
structure Due diligence
reporting
Create reports Import reports Aggregate (roll-up)
reports Perform validation
Checks
Adient / Conflict Minerals – Overview and Expectations 12
Conflict Minerals: Reporting Format
> The officially supported reporting format by AIAG
> The template is available in 9 languages already
> The latest version can be found here> It contains seven questions on the use of
tin, tantalum, tungsten and gold and the reporting status
> Ten questions are dealing with the overall company policy on Conflict Minerals
Select Language Preference Here:请选择你的语言:
사용할 언어를 선택하시오 :表示言語をここから選択してください :Sélectionner la langue préférée ici:
Selecione Preferência de idioma Aqui:Wählen sie hier die Sprache:
Seleccione el lenguaje de preferencia aqui:Selezionare la lingua di preferenza qui:
Burada Dil Tercihini Belirleyin:
English
Revision 4.10April 29, 2016
Company Name (*):Declaration Scope or Class (*):
Company Unique ID:Company Unique ID Authority:
Address:Contact Name (*):
Email – Contact (*):Phone – Contact (*):
Authorizer (*):
Title - Authorizer:
Email - Authorizer (*):Phone - Authorizer (*):
Effective Date (*):
1) Is the 3TG intentionally added to your product? (*) CommentsTantalum (*)
Tin (*)
Gold (*)
Tungsten (*)
2) Is the 3TG necessary to the production of your company’s products and contained in the finished product that your company manufactures or contracts to manufacture? (*) Comments
Tantalum (*)
Tin (*)
Gold (*)
Tungsten (*)
3) Do any of the smelters in your supply chain source the 3TG from the covered countries? (SEC term, see definitions tab) (*) Comments
Tantalum (*)
Tin (*)
Gold (*)
Tungsten (*)
4) Does 100 percent of the 3TG (necessary to the functionality or production of your products) originate from recycled or scrap sources? (*) Comments
Tantalum (*)
Tin (*)
Gold (*)
Tungsten (*)
5) Have you received data/information for each 3TG from all relevant suppliers? (*)Comments
Tantalum (*)
Tin (*)
Gold (*)
Tungsten (*)
6) Have you identified all of the smelters supplying the 3TG to your supply chain? (*)Comments
Tantalum (*)
Tin (*)
Gold (*)
Tungsten (*)
7) Has all applicable smelter information received by your company been reported in this declaration? (*) Comments
Tantalum (*)
Tin (*)
Gold (*)
Tungsten (*)
Question
A. Do you have a policy in place that addresses conflict minerals sourcing? (*)
B. Is your conflict minerals sourcing policy publicly available on your website? (Note – If yes, the user shall specify the URL in the comment field.) (*)
C. Do you require your direct suppliers to be DRC conflict-free? (*)
D. Do you require your direct suppliers to source the 3TG from smelters whose due diligence practices have been validated by an independent third party audit program? (*)
E. Have you implemented due diligence measures for conflict-free sourcing? (*)
F. Do you collect conflict minerals due diligence information from your suppliers which is in conformance with the IPC-1755 Conflict Minerals Data Exchange standard [e.g., the CFSI Conflict Minerals Reporting Template]? (*)
G. Do you request smelter names from your suppliers? (*)
H. Do you review due diligence information received from your suppliers against your company’s expectations? (*)
I. Does your review process include corrective action management? (*)
J. Are you subject to the SEC Conflict Minerals rule? (*)
Answer
Answer
Answer
Answer
Answer
Answer
Answer the following questions 1 - 7 based on the declaration scope indicated above
Answer
Company Information
Description of Scope:
Conflict Minerals Reporting Template (CMRT)
The purpose of this document is to collect sourcing information on tin, tantalum, tungsten and gold used in products Link to Terms & Conditions
Mandatory fields are noted with an asterisk (*).
Answer the Following Questions at a Company LevelCommentsAnswer
© 2016 Conflict-Free Sourcing Initiative. All rights reserved.