|Conflict mineral compliance can be a cloudy affair|
Apple hasn't been at the forefront of conflict mineral tracking for ethical or legal compliance, but their 2015 Supplier Report indicates the company is making progress.
"All tantalum smelters known to be in our supply chain remained verified as conflict-free throughout 2014," says the company in its recent report. Note the qualifying phrase, known to be in our supply chain; that phrase highlights both the central snag in supply chain material disclosure and one of the more popular loopholes. (It's what you don't know that can't hurt you. In theory.)
In early 2014, Apple says it introduced a deadline to smelters: be verified conflict-free or in the process by the end of 2014. If the deadline were missed Apple threatened to remove them from the supply chain.
Apple reports it more than doubled the number of verified conflict-free smelters to 135 in 2014, and another 64 are in the process of verification by the Conflict-Free Smelter Program (CFSP) or an equivalent independent third-party audit program.
According to Apple's 2015 report, four smelters were unwilling or unable to commit to be audited by a third party. Apple says it put those smelters "on notice" that they will be removed from the Apple tree.
It would be interesting to see a list of those four smelters.
It turns out, you can. Starting in 2011, and not a moment too soon, Apple began encouraging its supply chain smelters to comply with the CFSP (or an equivalent independent third-party audit program). To drive accountability and help stakeholders track progress, the company publishes a quarterly list of the names, countries — and CFSP participation status of the smelter and refiners in the supply chain.
The following smelters and refiners are suppliers to Apple that Apple has listed as "Not Participating" in third party audits despite pressure to do so from Apple. It looks like more than just the four they mentioned.
Apple Smelters / Refiners Not Participating in 3rd Party Audits
Name, Country, Metal
Bauer Walser AG, Germany, Gold
Caridad, Mexico, Gold
Chugai Mining Co., Ltd., Japan, Gold
Daye Non-Ferrous Metals Mining Ltd., China, Gold
Do Sung Corporation, Republic of Korea, Gold
Doduco GmbH, Germany, Gold
Gansu Seemine Material High-Tech Co. Ltd., China, Gold
Guangdong Jinding Gold Ltd., China, Gold
Hangzhou Fuchunjiang Smelting Co., Ltd., China, Gold
Hunan Chenzhou Mining Group Co., Ltd., China, Gold
Hwasung CJ Co. Ltd., Republic of Korea, Gold
Korea Metal Co. Ltd., Republic of Korea, Gold
Lingbao Gold Co., Ltd., China, Gold
Lingbao Jinyuan Tonghui Refnery Co. Ltd., China, Gold
Luoyang Zijin Yinhui Metal Smelting Co. Ltd., China, Gold
Penglai Penggang Gold Industry Co. Ltd., China, Gold
Samwon Metals Corp., Republic of Korea, Gold
Tongling Nonferrous Metals Group Holdings Co., Ltd., China, Gold
Torecom, Republic of Korea, Gold
Yunnan Copper Industry Co. Ltd., China, Gold
CNMC (Guangxi) PGMA Co. Ltd. China Tin
Gejiu Kai Meng Industry and Trade LLC, China, Tin
Gejiu Zi-Li, China, Tin
Huichang Jinshunda Tin Co. Ltd,. China, Tin
PT Seirama Tin investment, Indonesia, Tin
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd., China, Tungsten
From the Apple Quarterly Smelter List, February 2015, in the Apple Supplier Responsibility synopsis. For more information about Apple’s Supplier Responsibility Program, visit www.apple.com/supplier-responsibility.
In closing, conflict mineral compliance is not the easiest thing to achieve. But it can be done. And Apple can do it. It might not be the most desirable compliance activity in terms of logistics. But others have done it, and Apple, with cash reserves now topping $178 billion, is not without resources.