Conflict Minerals Report (CMR)

A Conflict Minerals Report (CMR) is a document filed by SEC registrants as an exhibit to Form SD when their RCOI and due diligence determine that conflict minerals may have originated in the DRC or adjoining countries and are not from recycled or scrap sources. The CMR must describe the due diligence measures taken, including the framework used (e.g., OECD Due Diligence Guidance), the facilities used to process the conflict minerals, the country of origin of the minerals, and efforts to determine mine or location of origin.

SEC Rule 13p-1; Exchange Act Section 13(p); Form SD, Item 1.01; SEC Final Rule on Conflict Minerals (August 22, 2012).

The CMR is the most detailed component of a company’s conflict minerals disclosure. It is publicly filed with the SEC and posted on the company’s website. The CMR must reference an internationally recognized due diligence framework — in practice, virtually all CMRs reference the OECD Due Diligence Guidance. Since 2017, the SEC Division of Corporation Finance has not enforced the requirement for an Independent Private Sector Audit (IPSA) of the CMR, though Form SD filing itself remains mandatory.

A U.S. auto parts manufacturer’s RCOI finds that it cannot rule out DRC origin for tungsten in its supply chain. It files a Form SD and attaches a CMR describing: OECD-aligned due diligence, the 47 tungsten smelters in its supply chain, the countries of origin identified, and its efforts to engage non-conformant smelters with RMAP.