Green Status Pro is selected to support our clients' Conflict Minerals Reporting Programs for three reasons.
#1 We are the low-cost provider.
#2 We are the highest-quality provider.
#3 We treat each client as though it is our only client.
We have obtained the capability to meet our clients' requirements better than alternative approaches through the skillful application of technology.
These FAQs explain how Green Status Pro is meeting the needs of compliance professionals for conflict minerals reporting.
How Did Green Status Pro Become the Low-Cost Provider?
Green Status Pro invested in developing proprietary technology to read Conflict Minerals Reporting Templates (CMRTs) and properly process the information extracted. This dramatically lowers the cost of the most critical procedure in conflict minerals reporting. This technology allows us to provide our clients with product-level and user-defined CMRTs with minimal incremental cost. And the data for custom reports is accessible on-demand.
We have selected, tested and implemented best-in-class, low-cost, cloud-based services to manage supplier communications and reporting procedures. This has significantly lowered the time and effort required to manage and document supplier communications -- the most time draining aspect of conflict minerals reporting.
Finally, Green Status Pro sells only to compliance professionals. This allows us to have lower sales and marketing expenses. We pass this substantial savings -- approximately 30% of the price alternative suppliers charge -- on to our clients
Who Else Offers a Service Similar to Green Status Pro?
Only the low-cost provider, Green Status Pro, can do so economically.
Effective global supply chain management is essential for achieving the humanitarian objectives of conflict minerals reporting. Global reporting requires all manufacturers -- private companies; small companies; European companies; Asian companies and more -- to properly report their source and use of 3TGs to their customers using the industry-standard CMRT form.
Clients report that Green Status Pro allows them to support their customers properly without needing to invest the time and money to become conflict minerals experts.
Green Status Pro meets the needs of manufacturers located anywhere in the world who must provide their customers with a CMRT, want it to be prepared correctly at the lowest cost possible and cause the least distraction for management.
Conflict minerals reporting requirements are neither well understood by users nor consistently interpreted by compliance professionals.
Creating a CMRT for a client is never the end of the engagement. There is always push back of some kind from at least one of our client's customers.
Ensuring that all our clients know they will have access to Green Status Pro support is one of our core values. We write it into all our client agreements without exception.
The members of the Responsible Minerals Initiative (RMI), formerly the Conflict-Free Sourcing Initiative (CFSI), have voluntarily taken on the responsibility of leading the efforts to end the funding of violence in the DRC region.
The RMI's Responsible Minerals Assurance Process (RMAP) is the cross-mineral industry standard for refiners and smelters that are willing to engage third-party auditors to affirm that they are following procedures to eliminate the acquisition of 3TGs from unknown sources. Very importantly, the RMI publishes on-line and for free the names of compliant, active and participating refiners and smelters.
In addition, CMRT Version 5.10 includes the RMI Smelter Look-up table. This table lists all RMI validated refiners and smelters. And, it is free -- our clients' favorite price.
Bottom Line: The RMI data Green Status Pro's clients require is both free (lowering costs) and more accurate than alternative sources (increasing report quality.)
Green Status Pro selected Dropbox to be the repository for our client's compliance documents because it is the best fit and provides must-have compliance functionality. To summarize the top 3 attributes:
Dodd-Frank Section 1502 is administered by the SEC. The SEC has communicated its "electronic document retention requirements." These include: retention of records for 5 years, data stored on non-rewritable media, data must be searchable, data must be readily retrievable and data must be stored off-site. Dropbox provides all this and much more;
Compliance Professionals can manage Dropbox without dedicated IT support:
Dropbox is affordable.
GoToMeeting allows Green Status Pro's compliance analysts and their clients to work together as though they are sitting at the same desk. The benefits are increased productivity and improved program quality -- all achieved without expensive in-person site visits.
How do Clients Describe Green Status Pro's Services?
The following statements are from clients' Form SDs
filed with the SEC in May 2018
Conduct Supplier Survey and Document CMRT Smelter List
We conducted a targeted survey of 240 of our strategic and core direct material suppliers. Based on these responses, 315 RMI confirmed smelters that process conflict minerals have been identified as potentially being in our supply chain. This is 98% of all recognized smelters worldwide. Of these, 262 smelters are confirmed conflict-free per the RMI database. 17 smelters source from the DRC or Covered Countries and are RMI certified conflict-free.
We believe that our inquiries and investigations represent a reasonable effort to determine the mines or locations of origin of the conflict minerals in our products, including:
1. Seeking information about conflict minerals smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT; and
2. Verifying those smelters and refiners with the RMI database.
Evaluate CMRTS and Provide Supplier Due Diligence Follow-up
With the assistance of Green Status Pro, a third-party resource for data analysis, the submitted CMRTs were reviewed for accuracy and validity. Green Status Pro's evaluation service was used to identify and evaluate smelter data against the data provided by the Conflict-Free Smelter Program. Many data inconsistencies were identified during this process, and verification efforts with the relevant suppliers are ongoing to resolve the data inconsistencies. We also continue to follow up with suppliers that have not yet responded to our requests for 3TG information.
Risk is assessed by reviewing information contained in the declaration tab of each supplier’s CMRT and by comparing the data contained in each supplier’s smelter list against the RMI smelter and refiner list. In CY17, our company utilized Green Status Pro, a third-party resource, for data analysis and subsequent aggregated declaration and consolidated smelter reports. These summary reports help identify risks associated with smelters in our supply chain that need to be addressed.
Green Status Pro was used to identify and evaluate smelter data against the data provided by the RMI. Data inconsistencies were identified during this process, and verification efforts with the relevant suppliers are ongoing to resolve them. We follow up with suppliers that do not respond to our requests for 3TG Minerals information in a timely manner. We are advising suppliers that failure to adequately respond to our request for 3TG Minerals information may result in loss of approved vendor status. Our Company has eliminated suppliers from our approved source list for failure to show reasonable effort or improvement in their reporting data.
Automate Reporting Process
We will continue to further automate our process with Green Status Pro to help validate CMRT submissions, identify any contradictory answers in the CMRT, and to help improve the overall accuracy and usefulness of the data provided.
Documentation related to the preparation of this report will be retained for a period of five years.
Supplier CMRT Analysis and Due Diligence Follow-up
Suppliers’ CMRTs were evaluated for completeness, accuracy of information and consistency in the responses to questions and smelter lists. The CFSI database was utilized as part of the assurance process. Suppliers were contacted in regards to CMRTs which contained errors and/or omissions, and were requested to resubmit a corrected CMRT.
What is the Relationship Between the RMI and the CFSI?
On October 25, 2017, the CFSI (Conflict-Free Sourcing Initiative) was re-branded as the Responsible Minerals Initiative (RMI). Over the last 2 years the CFSI has led the industry approach to Responsible Sourcing beyond conflict minerals. The CFSI originated as an electronics industry initiative but its supply-chain reporting methodology has expanded into other industries.
"The RMI will continue the CFSI mission and vision under its new name and brand and continue to provide programs, services and tools to encourage responsible minerals supply chains globally and assist companies with regulatory compliance," Source: EICC Becomes the Responsible Business Alliance and the CFSI the Responsible Minerals Initiative, October 25, 2017.
The table below translates CFSI into RMI. Green Status Pro now uses the RMI terms in all its reports and communications.
What is the Relationship Between the RMI and the CFSI?
How Will Green Status Pro Support the EU Conflict Minerals Regulation?
The 2017 European Union regulation requiring the reporting of the importation of conflict minerals is still a work-in-progress. The EU regulation requires that the first reports must be completed by January 2021. But the information required and the format are still being defined.
Green Status Pro believes that the EU will turn to the RMI to create a model European Conflict Minerals Reporting Program. The challenges for those organizations required to report will be to document that the appropriate procedures were followed, processing the European CMRT and accurately generating the correct reports.
Green Status Pro already has the technology and processes in place to cost-effectively provide our clients with the support to overcome all these challenges.
Bottom Line: Complying with the EU regulation will simply be an extension of the current service programs offered by Green Status Pro.
Why Doesn't Green Status Pro Offer RoHS and REACH Support?
RoHS and REACH services may be similar to each other but they are very different from Conflict Minerals Reporting.
The critical operational requirements for RoHS/ REACH service suppliers are to gather, verify and distribute composite information on specific component parts. There is little to gain in terms of productivity, quality or lower costs by attempting to put in place a robust compliance information infrastructure to further automate these basic functions. In addition, RoHS/REACH has minimal process requirements.
Conflict minerals reporting is very different. Automating the processes required for conflict minerals reporting results in significant client benefits. It is administered by the SEC (Securities and Exchange Commission). This puts the burden on our clients to maintain conformance with the SEC' electronic records retention rules and creating auditable documentation for a possible IPSA (Independent Private Sector Audit.)
Green Status Pro will only offer support services where we can make a significant improvement over existing methods. RoHS and REACH do not fall into this category.
Why Do Companies Prefer to Engage a CMR Specialist?
Retaining a CMR (Conflict Minerals Reporting) Specialist is becoming management’s preferred solution for achieving compliance excellence.
Conflict Minerals Reporting Specialists are professionals who have the experience and knowledge necessary to cost-effectively perform and document the OECD-recommended CMR tasks.
C-level executives are in a bind when faced with the straightforward question: “How should our company staff the Conflict Minerals Reporting Position?”
The two contradictory decision criteria are:
Maximize CMR Expertise.
Comparing the 5 possible options, it becomes very clear why engaging a Green Status Pro CMR Specialist is the preferred approach.
Option 1: Hire a Conflict Minerals Compliance FTE.
The annual cost of a qualified CMR FTE with benefits is 3-5 times the annual contract value of a Green Status Pro CMR Specialist and the workload required of the CMR FTE will be less than 90 days per year.
A Green Status Pro CMR Specialist easily meets both decision- making criteria – minimize cost and maximize CMR expertise – better than a CMR FTE.
Option 2: Engage a full-service compliance consulting firm that provides RoHS and REACH services in addition to Conflict Minerals Reporting.
Employing a full-service compliance consulting firm and the company’s Compliance Officer overseeing its work effort is the highest cost option;
The company obtains minimal institutional knowledge of its materials compliance requirements and its own procedures.
A Green Status Pro CMR Specialist is both significantly less expensive and provides a better source of knowledge transfer to the company for managing the company’s supply chain compliance obligations.
Option 3: Assign the Conflict Minerals compliance responsibility to a current supply chain staff member.
The typical outcome of assigning the CMR Program to an individual who is not experienced in compliance is the company’s CMR Program becomes a liability due to errors in the reporting procedures and lack of substantiation documentation.
A far superior and less costly approach is to engage a Green Status Pro CMR Specialist to report to a supply chain manager. The supply chain manager should need to spend less than 20 days per year working in collaboration with the CMR Specialist and the quality of the program should be excellent
Option 4: Cancel the company’s CMR Program.
The company will lose access to new sales opportunities that require a company-level CMRT;
The lack of a CMR Program communicates to employees, customers, suppliers and investors that the company cannot be relied upon to do the “right thing.”
Cancelling the company’s CMR program is not the low-cost solution it may seem. The company will doubtlessly incur numerous reputation, investor and sales revenue opportunity costs;
Engaging a Green Status Pro CMR Specialist will typically be less expensive than cancelling the company’s CMR Program.
Option 5. Engage a Green Status Pro CMR Specialist reporting to the employee responsible for creating the company’s CMRT.
A Green Status Pro CMR Specialist will bring the expertise that can only be acquired over time by working with numerous clients in multiple industries surveying thousands of suppliers, private and public, located throughout the world;
A Green Status Pro CMR Specialist will have the technology tools that provide the productivity and integrity required to perform the CMR tasks cost effectively and quickly;
For SEC Filers, the involvement of a Green Status Pro CMR Specialist should be referenced in their Form SD’s Conflict Minerals Report exhibit to demonstrate the corporation’s commitment to properly reporting its source and use of conflict minerals;
Making the Green Status Pro CMR Specialist the face of the company’s CMR program to suppliers, customers and employees will save management from many days of needless distraction.
Engaging a Green Status Pro CMR Specialist clearly meets management’s two contradictory criteria:
Maximize CMR Expertise.
Why Is It Difficult to Obtain CMRTs from Your Company's Suppliers?
For most companies, the most difficult and time-consuming task in the Conflict Minerals Reporting process is gathering data from suppliers. Green Status Pro CMR Specialists are skilled at cost-effectively surveying suppliers.
Through experience, they have learned that success in gathering CMRTs is directly related to the extent to which they know their clients’ suppliers.
Here are 4 highly significant aspects of the art of know-your-supplier that are frequently overlooked but critical to minimizing cost and maximizing supplier response rates.
Know Your Company’s Suppliers’ Real Names
Surprisingly, the art of gathering CMRTs begins with knowing the correct names of the suppliers.
A significant number of manufacturers have merged, sold or bought operating divisions, changed their names and corporate identities, or grown from local operations into global enterprises.
Too often, the supplier names provided to the CMRT team are out-of-date and incorrect.
Know Who Is Responsible for Providing the Supplier’s CMRT to Customers
The normal commercial communications between a supplier and its customer is handled by supplier sales reps and customer sourcing executives. The CMRT is not part of this transaction process.
Post-sales support is handled by the supplier’s customer support organization and the customer’s engineering and manufacturing departments. The CMRT is not part of this operational process.
Some manufacturers minimize CMRT-related costs by making their customers responsible for obtaining their own CMRT. Customers must know where to find the supplier’s CMRT on its website.
At the other extreme, there are many manufactures who require their customers to make formal requests through a compliance department and provide a list of the products purchased from the supplier before they will release their CMRT.
Green Status Pro CMR Specialists know from experience how the different manufacturers must be approached.
Distributors and Contract Manufacturers Hide Their Customers Identity
Gathering CMRTs becomes much more complex when a manufacturer’s products are sourced through a third-party.
Suppliers do not know who the ultimate customer is and are wary of providing a CMRT to non-customers. The third-party does not want to incur the costs of gathering CMRTs from its suppliers and distributing them to the correct customers.
The Art of CMRT collection is to successfully work through this barrier.
Identify Companies That Refuse to Create a CMRT
One of the responsibilities of the CMR Specialist is to identify suppliers who refuse to participate in the global CMR initiative.
These manufacturers can consume an inordinately high percentage of time by neither confirming nor denying they have a CMRT.
The Art of Data Collecting is to know how to minimize the time these Conflict Mineral Risks consume.
Green Status Pro’s clients have trusted us to gather CMRTs from thousands of suppliers.
We have proactively analyzed supplier organizations to provide our clients with an accurate understanding of who their current suppliers are. We have aggressively requested CMRTs or other Conflict Mineral Declarations.
Green Status Pro uniquely adds value to compliance organizations by documenting each supplier’s conflict minerals reporting program.
This results in cost-effectively obtaining the highest supplier response rates possible.