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Overview and Expectations
Conflict Minerals Overview and Expectations
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What are “Conflict Minerals”?
Dodd-Frank Wall Street Reform and Consumer Protection Act – Section 502 “Conflict minerals are minerals mined in conditions of armed conflict and human rights abuses…” These are the four conflict minerals (3TG): Coltan Tantalum Casserite Tin Wolframite Tungsten Gold Adient / Conflict Minerals – Overview and Expectations
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Conflict Minerals – Covered Countries
The Democratic Republic of the Congo and adjoining countries Adient / Conflict Minerals – Overview and Expectations
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Conflict minerals – Usage in the Automotive Industry
Picture source: AIAG report, May 2011 Adient / Conflict Minerals – Overview and Expectations
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Conflict minerals – Usage in the Automotive Industry
Picture source: AIAG report, May 2011 Adient / Conflict Minerals – Overview and Expectations
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Conflict Minerals Reporting
Why? Reporting obligation (part of the financial reporting to SEC) due May, 31st each year How? Following the OECD Due Diligence Guidance: Identify suppliers Receive declarations Perform plausibility checks Roll up final report and send to customer What? Information on the company policy on Conflict Minerals List of identified smelters from the complete supply chain Adient / Conflict Minerals – Overview and Expectations
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Conflict Minerals: Timeline
When? Possible status for a company: Indeterminate Not CM free CM conflict free CM free Sources for Conflict Minerals not yet fully known Some or all products contain 3TGs sourced from the DRC*, NOT from a conflict free smelter 3TGs are sourced from the DRC*, but from a conflict free smelter 3TGs for all products are NOT sourced in the DRC* Small, SEC filing companies only *DRC: Democratic Rebublic of the Congo Adient / Conflict Minerals – Overview and Expectations
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Conflict Minerals Reporting in Adient
To fulfill our requirements on conflict minerals reporting the following steps are needed: Register for the IPCMP platform. This is mandatory. The Basic Licence is free of charge Respond to our Initial Supplier letter within 30 days providing us with your IPCMP ID and the name and contact details of your CM contact Collect smelter information from your suppliers. Please use either IPCMP (recommended) or the CFSI template (link to the CFSI page) Use available IMDS data, the AIAG guideline and the AIAG decision tree to verify incoming data from your supply chain Submit your declaration to Adient. Include your vendor number and your IMDS company ID* to the company ID field of the CMRT * Only IMDS reporting companies Adient / Conflict Minerals – Overview and Expectations
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Conflict Minerals Reporting in Adient
Your tasks: Collect the Conflict Minerals data from your supply chain during the reporting year Submit your declaration until deadline Review and update your declaration thoughout the year Resubmit your final declaration until December 31, 2016 We will reject your submission when the reporting template is older than version 4.10 incomplete and incorrect data are identified in the declaration the 3TG declaration does not correspond to available material or component information Adient / Conflict Minerals – Overview and Expectations
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Appendix Adient / Conflict Minerals – Overview and Expectations
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Conflict Minerals: IT-Solution IPCMP by iPoint
Manage & respond to requests from your customers Send & manage requests to your suppliers Statistics of accepted reports All data in one place Sophisticated folder structure Due diligence reporting Create reports Import reports Aggregate (roll-up) reports Perform validation Checks Adient / Conflict Minerals – Overview and Expectations
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Conflict Minerals: Reporting Format
The officially supported reporting format by AIAG The template is available in 9 languages already The latest version can be found here It contains seven questions on the use of tin, tantalum, tungsten and gold and the reporting status Ten questions are dealing with the overall company policy on Conflict Minerals Adient / Conflict Minerals – Overview and Expectations
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