Supply Chain Policy (Conflict Minerals)

A supply chain policy for conflict minerals is a formal, publicly communicated statement of a company’s commitment to responsible mineral sourcing and its expectations of supply chain partners. It is required as Step 1 of the OECD five-step due diligence framework and is expected by the EU Conflict Minerals Regulation and Dodd-Frank. The policy should clearly state the company’s stance on conflict minerals, expectations for suppliers, and the consequences of non-compliance.

OECD Due Diligence Guidance, Third Edition (2016), Step 1; Regulation (EU) 2017/821, Article 4(a).

A conflict minerals supply chain policy is typically embedded in a company’s broader supplier code of conduct or stands as a dedicated policy document. It must be communicated to suppliers — often through supplier agreements, procurement terms, and annual CMRT outreach letters. The policy should reference the OECD Due Diligence Guidance as the company’s framework and specify requirements for CMRT completion, RMAP smelter participation, and consequences for non-cooperation. Posting the policy on the company website demonstrates public commitment.

A Fortune 100 electronics company’s conflict minerals policy states: all direct suppliers must complete annual CMRT declarations, all smelters in the supply chain must participate in RMAP, and suppliers failing to respond will be escalated to procurement for review. The policy is posted on the company website and incorporated into supplier agreements.