Contributing to a more secure, transparent, and fairer supply chain
The term “conflict minerals” covers minerals including those known as the 3TGs - columbite-tantalite or its derivative tantalum, cassiterite or its derivative tin, wolframite or its derivative tungsten, and gold. They are used in the design and manufacture of products and components such as those in the Information and Communications Technology (ICT) industry. The nature of the mining of these materials is often artisanal, small scale, and community based.
Companies who work with these minerals are often challenged on their decision to work in such difficult conditions. The supply chain between mine and final product owner can be 8-10 tiers deep, with potential challenges related to traceability of the minerals and supplier source, stability of the region and its governance, institutional weaknesses and corruption, widespread violence, human rights abuses, child and forced labor, as well as violation of international law.
Engaging to tackle a complex topic
The easiest choice for companies like our own would, in some minds, be to just ban the use of minerals from these regions and inform our suppliers not to engage, and believe that simply by cascading the requirement, there would be no risk of these minerals entering the supply chain. We have chosen to engage in tackling this complex topic, rather than looking the other way. We believe it is better to try to engender change from within by putting in place due diligence processes, collaboration, and training. However, we also understand that it does not guarantee immunity from the ingrained challenges in this industry and these regions, and we cannot do this alone. On the ground, we hope that we can potentially contribute to a more secure and transparent, and fairer supply chain with improved governance that has a positive impact in the region and on its communities.
We use a collaborative industry approach to tackle this complex issue. Responsible sourcing requires efforts from all stakeholders: governments, private companies, industry associations, non-governmental organizations, and civil society to secure and stabilize Conflict-Affected and High-Risk Areas (CAHRAs) worldwide.
Ensuring the traceability of minerals
Our core focus for the past decade has been on ensuring the traceability of minerals so that we know where those minerals are refined, and their origin (from which countries are the minerals extracted). This has meant primarily working on the downstream part of the supply chain (our tier 1-2-3 suppliers down to the smelters and refiners of the metals). Today we can say that we have identified 98% of the smelters and refiners who refine tin, tantalum, tungsten and gold in the supply chain of our products. We have further expanded our due-diligence to cobalt and mica and are expanding it further this year to include aluminum and copper – other critical minerals for our products.
In parallel, we have been working on the upstream part of the supply chain, all the way to the mine, as we look to ensure that all sources are validated as conflict free, using third-party audits through documented evidence. This work has included contributing to creating an independent third-party industry mechanism with the aim to ensure that upstream sourcing (from smelter to mine) is fully traceable and conducted in line with OECD due-diligence guidelines.
Our principal aim remains to support minerals supply chains in a conflict-affected region as long as they are conducted in line with OECD guidelines and successfully pass strict audits. For the upstream part, we have relied on industry collaborations such as the Public Private Alliance for Responsible Minerals to support the empowerment of regional stakeholders and ensure the supply of traceable and conflict-free minerals sourcing from the affected region. On top of our supplier audits, if we find or become aware of potential human rights abuses, we conduct a thorough investigation, determine if the associated mines are part of our supply chain and put in place the necessary plan for correction, remediation and potential exclusion of the mine in question.
Leveraging further benefits in our traceability approach
Our traceability work began with the aim of sourcing input materials for the components in our supply chain responsibly. This work has also provided us input for our value chain decarbonization journey and our circularity program. Having identified recyclers that our component suppliers use for gold on one end, we have been able to match those with recyclers that are used at the other end of our value chain (the recycling supply chain of our products at their end of life). This way proving that our supply chain can be truly circular – and we can actually direct our materials supply chain towards recyclers who have been refining our products to “new” materials for the market.
Our conflict minerals report outlines our approach in further detail
As part of our ongoing efforts to transparently outline how we are working in this area, the challenges we faced in 2023 (such as Russia-based smelters) and what our planned activities for 2024 are, we recently published our regular conflict minerals report which can be found here.
For further information on these issues there are some excellent resources, here are some of the many that are available: