Five Practical Steps for Conflict Minerals Due Diligence and SEC Disclosure Published by CFSI

Conflict-Free Sourcing Initiative Recommendations Support Responsible Sourcing and Reporting
Apr 12, 2017 2:45 PM ET
Press Release

ALEXANDRIA, Va., April 12, 2017 /3BL Media/ – The Conflict-Free Sourcing Initiative (CFSI), a coalition of leading companies dedicated to improving the security and human rights conditions in their raw materials supply chains, today announced the publication of an updated white paper that details practical steps for companies to meet SEC conflict mineral reporting requirements and conform to OECD Guidance.

The CFSI white paper, “Five Practical Steps for Conflict Minerals Due Diligence and SEC Disclosure,” provides clear explanations, practical tips and recognized practices for downstream companies on collecting and assessing information about the tin, tantalum, tungsten and gold (3TG) in their supply chains that should inform company decision-making and public reporting.

The white paper provides examples of how a company may use recommendations outlined in the OECD Guidance to meet SEC requirements by correlating the OECD Guidance 5-Step process to the SEC 3-Step process. The CFSI recommendations are based on reasonable approaches, many of which stem from lessons learned through years of company implementation, experiences across several industries, and the first three years of SEC reporting.

This version of the white paper, updated from 2015, includes additional options for companies that would like to implement recognized, progressive practices in their responsible sourcing programs. The progressive practices could be used by companies as they develop, review or revise their responsible sourcing programs and/or SEC filings.

“By sharing these recommendations, the CFSI hopes more companies will adopt similar practices, thus making responsible sourcing more efficient and ultimately more effective at mitigating conflict and other serious human rights abuses,” said CFSI Program Director Leah Butler. “If companies are considering adjustments to their due diligence systems or public reporting, the CFSI recommends they adopt an OECD-aligned approach.”

About CFSI

The CFSI is a multi-industry initiative with over 360 member companies, including associations and service providers. Our members contribute to the development and international uptake of a range of tools and resources, including independent third-party audit programs for smelters, the Conflict Minerals Reporting Template, Reasonable Country of Origin Inquiry data, and guidance documents on responsible sourcing of tin, tantalum, tungsten and gold (3TG). The CFSI runs regular workshops on responsible sourcing issues and contributes to policy development with civil society organizations and governments. For more information, visit

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