cfs audit procedure 3ts english
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xx Dec. 2012 EICC and GeSI CFS Audit Procedure Page 1 of 10 2012 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.
Conflict-Free Smelter (CFS) Program
Audit Procedure for
Tin, Tantalum, and Tungsten
Revision: 21 December 2012
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xx Dec. 2012 EICC and GeSI CFS Audit Procedure Page 2 of 10 2012 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.
The third party auditing firms must conduct the audits in accordance with the requirements in
ISO/IEC 17021:2011. A reasonable approach to making determinations should be employed as identified in the OECD Guidance
1 and the US SEC final rule.
2 Auditee shall not offer or accept
bribes or other means of obtaining undue or improper advantage. Within 24 hours of such an
event, the auditors shall notifiy the CFS program manager who will determine appropriate
actions on a case-by-case basis.
Auditors should refer to the audit checklist for further details.
Auditee must provide the following for the audit period:
1) The audit process will begin with the confirmation of the information provided by the auditee on the pre-audit checklist:
Name;
Location(s);
Types of tin/tungsten/tantalum containing feed materials received;
Complete list of suppliers for each type of tin/tungsten/tantalum feed material;
Types of tin/tungsten/tantalum products produced
Types of tin/tungsten/tantalum products sold
Tin/tungsten/tantalum products transferred to other locations
Tin/tungsten/tantalum materials transferred between other company locations
Unit operations on site where tin/tungsten/tantalum materials are processed. 2) The auditee will provide a copy of its policy related to procurement of
tin/tungsten/tantalum containing materials and the auditor will assess it against the
relevant section of the audit protocol.
3) The auditee will prepare for the audit by completing the Line Item Summary (total amount on a tin/tungsten/tantalum basis) for the audit period. The Line Item Summary is
to have been completed and returned to the assigned auditor 14 calendar days prior to the
audit start date. For practical purposes, the end of the audit period is marked by this date,
the date the Line Item Summary is provided. Generally, materials delivered between the
end of the audit period through the time of the audit will be validated during the
subsequence audit period. The auditors may inquire on the status of such material while
on-site as it pertains to differences noted between the Line Item Summary and actual
circumstances. The auditee must disclose the following information on the Line Item
Summary:
i. A list of all tin/tungsten/tantalum materials delivered to the facility from beginning of audit period to end of audit. This should be an exhaustive list of all
tin/tungsten/tantalum materials delivered to the facility including materials which
1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas, 15 December 2010. 2 Aug. 2012 final rule of the U.S. Securities and Exchange Commission (SEC) to implement the U.S. Dodd-Frank
Wall Street Reform and Consumer Protection Act, Section 1502 (Dodd-Frank) provisions on conflict minerals.
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xx Dec. 2012 EICC and GeSI CFS Audit Procedure Page 3 of 10 2012 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.
has been delivered and are in storage but has not yet been received into the
auditees management system.The auditee will provide a list of total estimated tin/tungsten/tantalum inventory at the beginning of audit period (one year prior to
the time of the audit) and at the end of the audit period, including inline.
Alternatively, the auditee may use the ending balance from their prior compliance
audit as the beginning inventory for the current audit period.
ii. The auditee will provide a detailed total tin/tungsten/tantalum sales and toll quantity on a monthly basis covering the entire audit period. The auditor will
select one random monthly sales lots. The auditee will provide the specific sales
receipts for that month. The auditor will sum up all sales receipts for that month
and match them to the total sales quantity provided. The auditor will expand the
scope to two additional random monthly sales lots if discrepancies are
encountered while completing the original one month inquiry.
Auditor must provide the following for the audit period:
4) The auditor will use the information provided by the auditee in the Line Item Summary (Step 3 above) to conduct a total tin/tungsten/tantalum material balance (+/-10%) for the
audit period to determine if the reported receipts, inventories, losses and sales figures are
in general agreement.
5) The auditor will inspect all relevant areas of the smelter (including on-site and off-site warehouses) to determine if all lots of tin/tungsten/tantalum received/purchased inventory
is accounted for/represented and if inventory exists which is not identified on the
submitted documents. The auditor will note if any inventory that was not identified on
the submitted documents should it be discovered during the warehouse inspection.
6) The auditor will review documentation for all (100%) receipts or purchases of tin/tungsten/tantalum ore, concentrate, intermediates, and partially processed and
byproduct materials for compliance to the 3Ts Audit Standard3. The auditor must be
able to reasonably conclude that material is conflict free, and must be able to identify the country of origin of the raw material for each material received. Exceptions will be
noted in the final audit report and will be considered in the auditors compliance
determination.
7) The auditor will review documentation for all (100%) existing inventory of tin/tungsten/tantalum ore, concentrate, intermediates, and partially processed and
byproduct materials purchased/received for compliance to the 3Ts Audit Standard. The
auditor must be able to reasonably conclude that material is conflict free, and must be able to identify the country of origin of the raw material for each material received.
Exceptions will be noted in the final audit report and will be considered in the auditors
compliance determination.
3 Conflict-Free Smelter (CFS) Program Supply Chain Transparency Smelter Audit Protocol for Tin, Tantalum and Tungsten
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xx Dec. 2012 EICC and GeSI CFS Audit Procedure Page 4 of 10 2012 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.
8) The auditor will then verify secondary tin/tungsten/tantalum-containing input materials based on the sampling methodology in the 3Ts Audit Standard to ensure it meets the
definition of secondary materials. Materials found not meeting the secondary materials
definition will be incorporated into items 6 and 7 noted above. If reasonable doubt exists
for >10% of the sampled secondary materials regarding meeting the definition of a
secondary material will result in a doubling of the sampling pool, up to 100% visible
analysis of the secondary materials.
9) The auditor will assess the OECD Guidance compliance audit of the due diligence process relied on by the auditee for material originating from a Level 3 country in
accordance with the 3Ts Audit Standard. The auditee must have available the tracking
and record keeping information validated by the OECD Guidance compliance audit that
provides reasonable assurance that the origin of the material is valid and conflict-free.
The overall result of the OECD Guidance compliance audit of the in-region sourcing
program is to be noted by the auditor in their final audit report to the ARC. This chain of
custody documentation audit report which is compliant to a credible OECD conformant
process is crucial to establishing confidence in the conflict free origin of material. The
auditor should thus review the report from the OECD compliance audit closely to ensure
it is credible and provides assurance the material is conflict free and report their
conclusions as to their assessment of such credibility. The auditor will also review the
information conveyed to downstream customers as well as publications of the smelters due diligence relative to Step 5 expectations of the OECD Guidance.
10) As possible, the auditor will summarize total tin/tungsten/tantalum receipts by country and mine of origin (see Line Item Summary) and compare to any independent data to
validate the plausibility of the stated sources of origin. The auditor may rely on multiple
sources of independent data including information provided my the auditee as related to
the smelter/refiners evidence gathered as a result of their due diligence activities.
11) The auditor will verify lot traceability by selecting at least three finished (sold) lots and follow the documentation back to the ore source (for continuous flow processes or inline
batch mixing this may include determining the total inline capacity and residence time of
the production line to predict incoming material lots as described in the 3Ts Audit
Standard). The selected three finished lots may cover materials outside of the provisions
of the audit (i.e. received materials prior to the audit period) so will only be used to
confirm lot traceability and not compliance. If irregularities are noted within the
traceability assessment that covers materials within the audit period then further
resolution as noted in the 3Ts Audit Standard is required. The traceability will follow the
three specific lots (excluding secondary materials) at each step of the process. Origin of
ore source will be reviewed and will impact compliance if within the audit period or will
be noted if outside of the audit period. Failure in matching product lots to incoming
material lots might not be possible and does not contribute to failure of the audit.
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xx Dec. 2012 EICC and GeSI CFS Audit Procedure Page 5 of 10 2012 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.
12) The auditor and auditee will conduct a closing meeting to present the audit findings and conclusions. Audit conclusion disputes should attempt to be resolved prior to auditor
creating the audit summary.
Auditee and Auditor must provide the following after the audit period:
13) As applicable, during a re-audit the material balance is recalculated including receipts and inventory change since the initial audit. The auditor will also verify that all non-
compliant procurement was discontinued from suppliers deemed CFS non-compliant on
the prior audit.
14) The auditor will prepare an audit summary report for the auditee and provide a copy to both the auditee and the CFS Audit Review Committee (ARC). In addition, the auditor
will provide to the ARC any supporting documentation necessary to enable ARCs review of the compliance conclusion including the audit report, line item summary and
audit checklist.
15) The ARC will determine compliance based on testimony, information and conclusions provided by the auditor, as well as any exception decisions made by the ARC.
Compliance or non-compliance conclusions will be communicated by the ARC to the
smelter/refiner.
Documents supplied to the auditor and used to complete the assessment
a) Audit Checklist (provided by the CFS program)
Checklist for implementing the audit
Audit Summary Results Template
b) Audit Line Item Summary (provided by the auditee)
Line item for summarizing documentation for each tin/tungsten/tantalum receipt
Explanation of Documentation items
OECD Guidance On the Ground Assessment Summary Report and other supporting reports and documents
c) Example Information (provided by the auditee)
Certificate of Origin (Acceptable/Unacceptable)
Export License
Certified Analysis/Sample (from variety of sources)
Mining License/Concession
Secondary Materials Example Lists (see the 3Ts Audit Standard)
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xx Dec. 2012 EICC and GeSI CFS Audit Procedure Page 6 of 10 2012 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.
Summary results of the audit
The audit will have five different potential outcomes at the conclusion of the audit review by the
auditor and Audit Review Committee (ARC):
1) Adequate documentation is available and reasonably demonstrates the source of all tin/tungsten/tantalum-containing purchases/receipts within the audit period as being
conflict-free minerals.
The audit result will be compliant.
2) The auditee refuses to participate in the audit process or does not provide adequate information or access to facilities to complete the audit. Auditor should take reasonable
means to resolve inadequate access while on-site by informing the auditee the
reprecussions of continued lack of auditor support. The auditor shall notify the Audit
Review Committee in the event an audit cannot be completed due to the auditees refusal
to participate or provide adequate facility access.
The audit result will be non-compliant.
3) There is insufficient documentation such that the auditor cannot reasonably substantiate the source of all tin/tungsten/tantalum-containing materials. The auditee cannot or does
not agree to provide further information.
The audit result is non-compliant.
4) Material from a level 3 source, exported without an OECD guidance compliant scheme being utilized, was found in the auditee records. A risk exists they may constitute not-
conflict free minerals (tin/tungsten/tantalum containing source from level 3 area which
was reasonably believed to have been received or exported [as noted on export
document] within the audit period).
The audit result will be non-compliant.
5) There is insufficient documentation to reasonably substantiate the source of all tin/tungsten/tantalum-containing materials. The auditee agrees to provide additional
information to address documentation deficiencies identified by the audit (see Continuous
Improvement Plans). The additional information will be supplied to the auditors within 2
months. A follow-up assessment (as required by the auditor) will be completed within
one additional month. The auditor will then determine if adequate information has been
provided to reasonably substantiate the source of the tin/tungsten/tantalum containing
materials.
The result is compliant if adequate documentation is provided (see 1 above). The result will be non-compliant if insufficient documentation remains after completing
the Continuous Improvement Plan.
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xx Dec. 2012 EICC and GeSI CFS Audit Procedure Page 7 of 10 2012 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.
Continuous Improvement Plans
Should an auditee be found to be non-compliant by outcome #5 above, then a continuous
improvement plan needs to be implemented and verified prior to becoming compliant. The
details of the improvement plan will be agreed to between the auditee and the CFS Audit Review
Committee (ARC).
If any lot of incoming tin/tungsten/tantalum ore or tin/tungsten/tantalum-containing material is
identified to be non-compliant (insufficient documentation and reasonably identified to be not-
conflict free) then the auditee should quarantine this material immediately until reviewed by the
ARC to discuss disposition. Material with inadequate documentation but reasonably identified
to be conflict free does not need to be quarantined.
The auditees continuous improvement plan must contain the following elements:
1) Providing sufficient documentation to the auditor to reasonably substantiate the source of all tin/tungsten/tantalum-containing materials. The auditee may work with the supplier
of the non-compliant material to obtain follow-up documentation as a means to further
document/justify it to be conflict free.
2) Disposition of any non-compliant tin/tungsten/tantalum material (inadequate documentation and reasonably identified to be not-conflict free mineral as per the 3Ts
Audit Standards) must be reviewed and approved by the ARC prior to taking any action.
This material must remain in the as-received tin/tungsten/tantalum-containing material
state as it was originally purchased by or provided in a tolling agreement to the auditee
(or in semi- or final processed state, if applicable), as it is described in the Line-Item
Summary until the ARC and the auditee agree to a disposition plan. This will only apply
to tin/tungsten/tantalum-containing material still residing at the auditee during the audit
which is reasonably believed to be not-conflict free.
3) Disposition of any non-compliant tin/tungsten/tantalum (inadequate documentation but reasonably identified to be conflict free) may need to be verified by the auditor when
complete. Utilization of this material (or inadequate disposition action) by the auditee
without the approval of ARC will result in immediate non-compliance. The auditee may
work with the supplier of the non-compliant material to obtain follow-up documentation
as a means to further document/justify it to be conflict free. The auditee must provide all
additional documentation to the auditor and ARC for validation and approval prior to
consuming the non-compliant material as specified in the Continuous Improvement Plan.
4) Documented changes in the auditees purchasing policies and recognition of prior issues. These changes must be implemented within a three-month period following the audit.
5) A verification audit (re-audit) conducted by the initial auditor may be required to ensure the auditee has implemented the corrective actions identified in the Continuous
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xx Dec. 2012 EICC and GeSI CFS Audit Procedure Page 8 of 10 2012 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.
Improvement Plan including the disposition of the non-compliant tin/tungsten/tantalum
material and changes to purchasing policies. The re-audit will primarily focus on
validation of all non-compliant items identified in the Continuous Improvement Plan, as
well as new materials delivered since the initial audit.
6) After reviewing information from the second audit (or subsequent re-audits) then the ARC will determine whether that auditee can be identified as compliant or whether
additional actions are required. For example a more frequent audit schedule may be
required for the future.
7) Any auditee that has a repeat non-compliance issue identified, or was unable to complete closure on open items within the three-month post audit continuous improvement plan period will be deemed as non-compliant (subject to the final review by the CFS Audit Review Committee mentioned in step 4) and will be exempted from participating in the CFS program for a period of six months.
Disclosure and non-disclosure agreements
Compliant smelters/refiners will be posted on the EICC and GeSI websites and made available
publicly. Additionally the CFS policy of the auditee will also be posted. Country of Origin
Information (COI) will be provided to supporters of the CFS Program for their due diligence
needs. COI may provided directly or posted for supporters to access. The detailed data collected
during the audit will be made available only to the CFS Audit Review Committee (ARC) to
ensure consistency, compile anonymous aggregate information and identify common issues.
ARC members who have access to the detailed information are bound by NDAs with EICC and
GeSI, to not share the audit details outside the committee. The ARC will be primarily comprised
of final OEMs (e.g. Apple, HP, Intel, RIM, etc.) as well as an academic representative. The audit
details will not be distributed outside of the Committee. Only in the case of an appeal by the
auditee to the CFS Audit Program Manager might any relevant portions of the audit details be
provided beyond the ARC. NDAs will be implemented separately between the auditing firm, the
ARC and the individual auditee.
Public disclosure regarding CFS programs
Names and addresses (of facilities) of compliant smelters/refiners
Each smelters/refiners CFS policy
Country of Origin Information from all current audits
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xx Dec. 2012 EICC and GeSI CFS Audit Procedure Page 9 of 10 2012 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.
About EICC (Electronic Industry Citizenship Coalition)
The EICC was established in 2004 to improve social, economic, and environmental conditions in the
global electronic supply chain through use of a standardized code of conduct. The EICC was incorporated
in 2007 as an association to ensure greater awareness of the Code, and to expand its adoption across the
industry. The EICC includes over 75 global electronics companies. For more information or to view the
EICC Code of Conduct, see www.eicc.info or the latest annual report.
About GeSI (Global e-Sustainability Initiative) The Global e-Sustainability Initiative (GeSI) is an international strategic partnership of the Information
Communications Technology (ICT) sector and organisations committed to creating and promoting
technologies and practices that foster economic, environmental and social sustainability. Formed in 2001,
GeSIs vision is a sustainable world through responsible, ICT-enabled transformation. GeSI fosters global and open cooperation, informs the public of its members voluntary actions to improve their sustainability performance, and promotes technologies that foster sustainable development. GeSI has 32 members
representing leading companies and associations from the ICT sector. GeSI also partners with two UN
organizations - the United Nations Environment Program (UNEP) and the International
Telecommunications Union (ITU) - as well as a range of international stakeholders committed to ICT
sustainability objectives. These partnerships help shape GeSIs global vision regarding the evolution of the ICT sector, and how it can best meet the challenges of sustainable development. For more
information, see www.gesi.org.
For more information, contact:
Mike Loch Bob Leet GeSI EICC
Extractives Work Group Co-Lead Extractives Work Group Co-Lead
Board Representative
Michael.loch@motorolasolutions.com bob.e.leet@intel.com
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xx Dec. 2012 EICC and GeSI CFS Audit Procedure Page 10 of 10 2012 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.
Revision History
Rev 21 December 2012 Changes: Consolidation of Audit Procedure into one document in support of 3Ts Audit Standard
release.
Rev 15 September 2011 (Sn), 09 August 2011 (W), 15 January 2011 (Ta) Changes: Initial release as part of the tin protocol.
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