Extended Corrective Action Plan

Companies on the Extended Corrective Action Plan (ECAP) list are non-conformant to RMAP standards, as determined by their recent RMAP independent third party assessment.

While companies on this list are currently non-conformant, they have committed to address outstanding issues going forward and have agreed to the following conditions: 

  • Senior management (General Manager, Managing Director, or Owner) support for participating in an ECAP, implementing the Corrective Action Plan (CAP), and following the below requirements in a written communication to RMI
  • Publication of the following information on the company’s website:
    • Full Corrective Action Plan (CAP), including a description of changes being made to the company’s due diligence system prior to the next RMAP assessment
    • Measures to validate the origin of materials and due diligence from non-RMAP validated sources
  • Consultation by an external resource (e.g. consulting or advisory firm) to review changes prior to the next RMAP assessment
  • Submitting a timeline for the next RMAP assessment
  • Undergoing a full RMAP assessment once the CAP has been implemented
  • Regular communication with RMI
  • All follow-up public communication or status reports shall be done by the company and not by RMI staff

 

Smelters Undertaking Extended Corrective Action

There are currently no smelters that are undertaking an ECAP.

 

Continued Improvement and Timelines

ECAP progress must be made within the initial 90 days from notification of being on the list. Any failure to proceed with the above benchmarks and assessment scheduling within the initial 90 days will result in a warning communication. A warning must be acknowledged within 30 days or it will be followed by removal from the ECAP list.

In the event that a non-conformant smelter or refiner is unable to meet the ECAP requirements and close out non-conformances within a 12-month period from the enrollment date, then there shall be a final warning communication to the company, followed by ending their participation in the ECAP program.

The RMI is authorized to share with RMI members a general description about the CAP timeline and progress, updates on the timeline and preparation for the next RMAP assessment, and updates on supplier due diligence, and reports of any CAP issues.