AVX Corporation is piloting a new project for the Solutions for Hope program that tests new options for responsibly sourcing tin, tantalum, and tungsten (the 3Ts) from Rwanda. AVX and Motorola Solutions created the program in 2011 to test the feasibility of responsible and traceable sourcing of tantalum from the Democratic Republic of Congo (DRC).
U.S. legislation under the Dodd-Frank Act of 2010 requires publically-traded companies to disclose the use of certain minerals - tin, tantalum, tungsten and gold - in their products that are mined from the DRC and several other regions. They also must disclose the process they used to ensure that their purchase of these minerals were “conflict-free” and not funding illegally armed forces in the DRC and adjoining countries involved in a civil war.
The 3Ts Due Diligence Options Pilot will test two due diligence options for procuring responsibly-sourced tantalum from Rwanda. These include a new, cloud-based due diligence process developed by the Better Sourcing Program (BSP) used in combination with AVX’s Geological Passporting chain of custody system.
Here’s how it works. The BSP tool uses a proprietary phone app to enable real-time electronic monitoring, chain of custody tracking, and reporting of issues, which the company said provides much faster access to data than existing systems. The AVX Geological Passporting system determines the mineralogical, geochemical, and geochronological characteristics of ore at each mine. This is expected to help validate origins, reduce smuggling, and reduce the cost of due diligence processes, according to AVX.
“The goal of this pilot is to seek systems scalable to risk, with cost structures that avoid placing undue burden on upstream partners," said Willing King, senior vice president AVX, in a statement. "The end goal is to do this while meeting internationally accepted guidance and standards for due diligence, and keeping data management and reporting capabilities in line with current technology, as well as with the expectations of businesses, governments, and civil society."
The initiative recently had its first shipment audited and achieved full compliance by the Conflict-Free Smelter Program. This marks “a crucial first milestone in testing the readiness of these systems for commercial use,” said AVX.
Working with the Solutions for Hope Project, AVX selected key suppliers, which includes BSP-supported mines, exporter Rwanda Pure Water, and processor Global Advanced Metals, to create a closed-pipe supply line for testing. The company also engaged stakeholders from civil society, government, and industry to deliver transparency and knowledge sharing during the evaluation process.
The first shipment was received by Global Advanced Metals in August, and was among the tantalum receipts evaluated in the smelter’s most recent independent third-party audit, according to AVX. The audit was conducted by the Conflict-Free Smelter Program (CFSP), which found the smelter in compliance with all CFSP protocols.
Solutions for Hope plans to work with stakeholders to evaluate the 3Ts Due Diligence Options Pilot in an effort to improve and expand the program.
A recent report, Conflict Mineral Benchmarking Study RY2015, conducted by Development International, indicates that electronic component manufacturers are doing relatively well in the area of compliance and due diligence. “Many of these companies have been at the ground level—even involved in documentaries about the exploitation of mine workers—they care about this program,” according to Jonathan Nauth, program manager, Assent Compliance Inc.
There are positive risk-management aspects to compliance, according to Dr. Chris Bayer of Development International, who conducted the benchmarking study. “These companies can say ‘we are effectively managing our risk and we can be recognized by our stakeholders that we are doing our part.’ These companies are applying sensible policies [toward CSR] to make sure they are not doing more harm than good.”
Companies that filed as "DRC conflict free" and that filed an independent audit (IPSA) include AVX along with AMD, Arrow Electronics, Canon, China Mobile, Intel, Kemet, Philips NV, M/A-COM, Siliconware Precision, Skyworks, Smart Technologies and Texas Instruments.