Conflict Minerals - Adient · 2018-06-21 · Have you implemented due diligence measures for conflict-free sourcing? (*) F. Do you collect conflict minerals due diligence information

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

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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.