Survey Results: Conflict Minerals


1. We are a downstream company (ie. uses minerals in design/manufacture) required to conduct a "reasonable country of origin inquiry" (RCOI) and our process is: (Total responses: n=40)
(select only one)
n=26 (65.00%) Engage 1st-tier suppliers with questionnaire; review responses; check any smelters identified against independent verified lists; no further action if no reason to believe from responses received (even if less than 100% response rate) that the conflict minerals may have originated in the covered countries
n=10 (25.00%) Engage 1st-tier suppliers with questionnaire; review responses; check any smelters identified against independent verified lists; for unresponsive suppliers, perform further engagement (including 2nd-tier and above)
n=0 (0.00%) No direct engagement with suppliers; rely solely on smelters identified on independent verified lists
n=0 (0.00%) Outsource entire process to 3rd-party service provider & rely on their conclusions
n=4 (10.00%) Other

2. We are a downstream company that sends questionnaires to 1st-tier suppliers and they're non-responsive/unable to answer completely and our next step is: (Total responses: n=39)
(select only one)
n=1 (2.56%) Nothing, we're done - and will disclose that we have no reason to believe that conflict minerals may have originated in the covered countries
n=32 (82.05%) Further engage 1st-tier supplier (eg. calling, e-mails) but not 2nd-tier supplier, etc.
n=4 (10.26%) Further engage 1st-tier supplier, 2nd-tier supplier, etc.
n=2 (5.13%) Other

3. If you choose "a" in #2 above, would you consider the company to have satisfied its RCOI obligation: (Total responses: n=21)
(select only one)
n=5 (23.81%) Yes
n=8 (38.10%) No
n=3 (14.29%) Depends on what others are doing
n=5 (23.81%) Not sure

4. Are you taking measures to ensure that your RCOI covers new products manufactured by the company up until December 31st: (Total responses: n=37)
(select only one)
n=8 (21.62%) Yes, we have controls to monitor for new products with conflict minerals on a real time basis
n=4 (10.81%) Yes, we have controls to monitor for new products with conflict minerals on a quarterly basis
n=6 (16.22%) Yes, we have controls to monitor for new products with conflict minerals on a semi-annual basis
n=9 (24.32%) Yes, we perform our RCOI once per year as of December 31
n=10 (27.03%) No, we perform our RCOI earlier in the year and do not worry about scanning for new products through December 31

5. Has your company adopted a conflict minerals policy: (Total responses: n=39)
(select only one)
n=20 (51.28%) Yes, we are adopting one responding to the new rule
n=0 (0.00%) Yes, we had one prior to the new rule
n=0 (0.00%) Yes, we had one prior to the new rule, but have updated it for the new rule
n=13 (33.33%) No, but we're considering it
n=6 (15.38%) No, and we don't plan to

6. If your company had to perform Step 3 of the new rule, how long did it take (soup-to-nuts) (Total responses: n=26)
(select only one)
n=1 (3.85%) 0-3 months
n=5 (19.23%) 3-6 months
n=6 (23.08%) 6-9 months
n=6 (23.08%) 9-12 months
n=8 (30.77%) More than 12 months