Smelter or Refiner (SOR) Validation
Smelter Validation With GreenSoft Technology
One of your due diligence responsibilities as a manufacturer is to make a reasonable effort to ensure you’re using accurate information from your suppliers.
Validating smelters or refiners (SORs) from the Conflict Minerals Reporting Template (CMRT) and Extended Mineral Reporting Template (EMRT) forms provided by your suppliers has become a key responsibility due to Reasonable Country of Origin Inquiries (RCOI) guidelines.
GreenSoft Technology offers smelter validation as an optional service for our Conflict Minerals data collection program. Let GreenSoft do the leg work of smelter validation so you can focus on your core competencies.
The Validation Process
With our Smelter Validation Service, SOR information provided on CMRTs and EMRTs will be checked against several organizational databases to make sure the SOR is legitimate, such as the SORs List from Responsible Minerals Initiative (RMI), London Bullion Market Association (LBMA), Responsible Jewellery Council (RJC), Dubai Multi Commodities Centre (DMCC), and others.
When issues are found, further validation of data demands regular and structured communication with suppliers to clarify or correct CMRTs/EMRTs. We will contact your suppliers for you as many times as it takes to obtain accurate and complete information. Sometimes communication directly with SORs themselves is required.
If your SOR has been confirmed as legitimate but not yet CFSP Compliant, we will also request the SOR’s plan and timeline for becoming CFSP Active or CFSP Compliant. “CFSP Compliant” is the industry standard for SORs created by the Responsible Minerals Initiative (RMI) to ensure that smelters or refiners are conflict-free.
Our Data Collection team speaks many different languages to help facilitate supply chain communication, and you can access the collected documents from GreenData Manager software so that you can reference them anytime and display your due diligence.
Annual Deadlines and Reporting Requirements
The deadline for submitting conflict minerals reports to the SEC is May 31 of every year for the reporting period of the prior year. All publicly-traded companies that are subject to the rule must submit reports, and consumer demand is pushing even out-of-scope companies into voluntary compliance.
Additionally, the requirements for due diligence are getting more and more complicated. Besides collecting CMRT and EMRT forms from your supply chain, which will demand tremendous effort in numerous communications with your suppliers, you now are required to contact the smelters or refiners directly or work through your supply chain to validate the SOR status.
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