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Conflict-Free Sourcing Initiative

Conflict-Free Sourcing Initiative

The industry-led due-diligence body for tin, tantalum, tungsten, and gold from the African Great Lakes region

International jewellery standardsView in dictionary · 820 words

The Conflict-Free Sourcing Initiative (CFSI), now operating as the Responsible Minerals Initiative (RMI) since 2017, is the principal industry-led due-diligence body for the conflict-minerals supply chain, focused initially on tin, tantalum, tungsten, and gold (collectively the "3TG minerals") sourced from the Democratic Republic of the Congo and adjoining countries. The Initiative was founded in 2008 by the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI), and it has since expanded its scope to cover a broader set of minerals and a wider geographic footprint, while continuing to support the disclosure obligations of companies subject to Section 1502 of the United States Dodd-Frank Act.

Origins and the Dodd-Frank context

The Initiative was created in response to growing evidence that revenue from artisanal and small-scale mining of tantalum (used in electronics capacitors), tin (in solder), tungsten (in cutting tools and electronics), and gold in the eastern Democratic Republic of the Congo and adjoining countries was funding armed groups responsible for serious human-rights abuses. The 2008 founding predated the United States Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, but Section 1502 of that Act, requiring publicly listed companies to disclose their use of conflict minerals from the covered countries, gave the Initiative its principal regulatory tail-wind. Companies subject to Section 1502 - principally electronics manufacturers, automotive companies, aerospace firms, and increasingly jewellery and consumer-goods companies - looked to industry-led mechanisms to perform the due diligence required for compliance, and the Initiative provided the principal such mechanism.

The Conflict-Free Smelter Program

The Initiative's core operational mechanism is the Responsible Minerals Assurance Process (RMAP), formerly the Conflict-Free Smelter Program (CFSP), which audits smelters and refiners against a set of criteria designed to verify that the materials they process come from sources that do not finance conflict. Smelters and refiners that pass the audit are listed as "conformant" and are accepted by participating downstream companies as conflict-free sources. The list of conformant smelters and refiners, published by the RMI and updated regularly, is the principal industry reference for compliance. As of the 2020s the list includes hundreds of conformant gold refiners, tin smelters, tantalum processors, and tungsten processors worldwide.

The Conflict Minerals Reporting Template

For company-level reporting, the Initiative developed the Conflict Minerals Reporting Template (CMRT), a standardised Excel-based tool used by companies to gather information from their suppliers about the smelters and refiners in their supply chains. The CMRT is the most widely used due-diligence reporting tool for Section 1502 compliance and has been adopted by tens of thousands of companies in their supplier-engagement programmes. A separate Cobalt Reporting Template (CRT) was added in 2018 to address the cobalt supply chain, particularly cobalt from artisanal sources in the Democratic Republic of the Congo associated with electric-vehicle and consumer-electronics demand.

Expansion of scope and the 2017 rename

In 2017 the Initiative was renamed the Responsible Minerals Initiative, reflecting its expanded scope beyond conflict minerals strictly defined to include broader responsible-sourcing concerns. The RMI now addresses cobalt, mica, copper, nickel, aluminium, and other minerals in addition to the original 3TG, and its standards have been integrated into the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The original CFSI brand persists in some legacy documents and in industry shorthand.

Relationship to the Kimberley Process and to the gem trade

The CFSI/RMI is distinct from the Kimberley Process Certification Scheme, which addresses rough diamonds, but the two bodies operate in adjacent regulatory space and increasingly cooperate on overlapping issues. The CFSI/RMI's gold standards are particularly relevant to the jewellery trade, since gold from artisanal sources in the eastern Democratic Republic of the Congo has been a documented source of conflict financing, and the Responsible Jewellery Council and CIBJO standards for gold sourcing draw substantially on the CFSI/RMI's smelter-audit framework. For the jewellery trade specifically, the principal practical effect of the Initiative's work is the conformant-refiner list for gold, which provides downstream jewellers with a recognised mechanism for sourcing gold from refiners that have undergone third-party due-diligence audits.

Place in the international standards landscape

The Initiative occupies a central position in the international due-diligence ecosystem alongside the OECD's Guidance, the Kimberley Process, the Responsible Jewellery Council, the London Bullion Market Association's Responsible Gold Guidance, the Dubai Multi Commodities Centre's Responsible Sourcing Guidance, and the various national regulatory regimes (Dodd-Frank Section 1502 in the United States, the EU Conflict Minerals Regulation effective from 2021, and others). It is industry-funded and industry-governed, which has drawn some criticism from civil-society organisations who argue that the audit process is insufficiently independent, but it is the most widely adopted operational mechanism in the field and forms the practical backbone of corporate conflict-minerals compliance for a substantial portion of the global manufacturing economy.