Cobalt Reporting Template
RMI has launched a pilot Cobalt Reporting Template (CRT) for the identification of choke points and collection of due diligence information in the cobalt supply chain. The pilot phase will run from 1 March 2018 to 31 August 2018 and refinements and continuation of the tool will be assessed at the close of the pilot. The objectives of piloting the Cobalt Reporting Template are to:
- Understand its use/uptake in the supply chain
- Gain insight, collect, and analyze information the CRT provides (e.g., list of cobalt refiners, data on cobalt supply chains, current cobalt risk management practices)
- Identify opportunities to further improve upon the CRT’s content, format, etc.
DOWNLOAD THE COBALT REPORTING TEMPLATE HERE
FOR A LIST OF CURRENTLY IDENTIFIED COBALT REFINERS, CLICK HERE.
The cobalt refiner disposition process to review and add additional cobalt refiners is ongoing. To submit the name of a refiner that is not currently on the Standard Smelter List, download and complete the Smelter Information Questionnaire (CHI | KOR also available). Submit completed forms to email@example.com.
Pilot Scope: The CRT is available for interested companies to use within their cobalt supply chains in accordance with each company’s own program.
Implementation plan and timing:
- Pilot phase: March 1 to August 31, 2018. During this time, companies can use the tool, which is made available on the RMI webpage. Any feedback on the tool can be submitted via the survey above or by emailing firstname.lastname@example.org.
- Feedback period: RMI will issue a user survey to collect feedback on the CRT via a formal process. Feedback will be gathered and assessed from September 1, 2018 to October 1, 2018. Pilot status and results will be shared at the RMI Annual Conference and Members Meeting October 31 – November 2, 2018.
- Decision on continuation of the tool by December 2018.
Frequently Asked Questions
- What is the Cobalt Reporting Template (CRT)?
- The Cobalt Reporting Template (CRT) is a free, standardized reporting template created by the Responsible Business Alliance® (RBA®). The CRT facilitates the exchange of information through the supply chain regarding mineral country of origin and smelters and refiners being utilized. In doing so, it supports companies’ exercise of due diligence in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The CRT also facilitates the identification of smelters and refiners.
- The CRT was designed for downstream companies to gather and disclose information about their supply chains. RMI members collaboratively developed this tool to create efficiencies and simplify the supply chain surveying process. Downstream companies include those companies from the end user up to but not including the smelter. If your company is a smelter or refiner, we recommend you enter your company’s name in the smelter list tab.
- The CRT is limited to cobalt supply chains.
- Why is the CRT different from the CMRT?
- The CMRT follows the IPC-1755 Standard, which does not currently include cobalt or questions related to the cobalt supply chain.
- The CMRT is intended, in part, to facilitate the exchange of data necessary for compliance with Section 1502 of the Dodd-Frank Act. There are no regulatory compliance requirements in place for cobalt at this time.
- What is a Conflict-Affected and High-Risk Area and how do I know if I am sourcing from one?
- The OECD defines conflict-affected and high-risk areas as areas that are identified by the presence of armed conflict, widespread violence or other risks of harm to people. Armed conflict may take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may consist of wars of liberation, or insurgencies, civil wars, etc. High-risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure and widespread violence. Such areas are often characterized by widespread human rights abuses and violations of national or international law.
- The European Union defines conflict-affected and high-risk areas as areas in a state of armed conflict, fragile post-conflict areas, as well as areas witnessing weak or non-existing governance and security, such as failed states, and widespread and systematic violations of international law, including human rights abuses
- While there is no definitive list of conflict-affected and high-risk areas, each company can utilize the resources provided here to make that determination.
- On Question 2, an answer of “Unknown” is an acceptable response.
- Why are some of the cobalt refiners on my suppliers’ lists not recognized by the CRT?
- The RMI maintains an up-to-date Smelter Reference list. This list contains all cobalt refiners that have been validated by the RMI to meet the definition of a cobalt refiner. There are several reasons why a supplier may provide refiners not listed in the CRT. Examples of reasons include: the company does not process cobalt, the company is upstream or downstream of a refiner, the company has yet to be validated as eligible through RMI’s Smelter Disposition Process or the company is no longer in operation and has been removed from the Smelter Reference List. One way to check the status of a SOR that is not on the Smelter Reference list is to become a RMI member, which gives companies access to the RMI’s smelter database.
- The cobalt refiner definition applied by the RMI is “An entity that processes cobalt concentrates, intermediates or recycled feed and produces a cobalt product for direct use in a downstream manufacturing process.” This does not include upgrading or refining facilities associated with large scale mining operations and / or in-country in the Democratic Republic of Congo if these provide outputs that require further refining before being applied in the downstream manufacturing process.
- Where do I submit my completed CRT? Does RMI collect these?
- The RMI does not collect CRTs. CRTs should be provided to your customers and as a good practice measure, and may be posted on your external web site.
- What is the reporting period for the CRT?
- While there is no legal requirement for companies to follow a specific reporting period, RMI recommends using the previous calendar year. In the pilot phase, this would be January 1 – December 31, 2017.
- Where can I find additional due diligence information?
- The Responsible Cobalt Initiative (RCI) and the RMI are developing a joint pilot audit program for cobalt refiners. More information about the program will be posted on the RMI webpage as it becomes available.
- Does “child labor” refer to all forms of child labor?
- Due to comments, in the next revision this will be updated to “worst forms of child labor.” The intention of this question is to capture “worst forms of child labor.” Accordingly, in the pilot version, the policy should cover at least all risks in the OECD Annex II Model Policy.
- How should I provide multiple answers for Question 2?
- In this version of the CRT you cannot select more than one option from the dropdown for Question 2. However, you should use the comment section to add notes to this effect, for example by selecting “covered countries” and putting a comment, “and other CAHRAs, including XYZ.”