Update: June 25, 2024

How to Complete a Conflict Minerals
Reporting Template (CMRT)CMRT Rev. 6.4
July 2024
Japan Electronics and Information
Technology Industries Association (JEITA)- Responsible Minerals Trade Working Group 【Notice】
This document is published by the JEITA Responsible Minerals Trade Working Group.
We endeavor to ensure that our information is as recent and accurate as possible, but please beaware that this will not always be the case.

Table of Contents
1. Conflict Minerals Survey

2. CMRT Rev. 6.4 Outline and Changes
3. How to Complete the CMRT
3.1 Declaration Sheet
3.2 Smelter List Sheet
3.3 Product List Sheet
3.4 Checker Sheet
Reference Information2© 2024 JEITA

1. Conflict Minerals Survey

3© 2024 JEITA

1. Conflict Minerals Survey: Background
What is the Conflict Minerals Survey?
This survey is a way to respond to the requirement since May 2013 under the US DoddFrank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act: DFA) that the
US-listed companies investigate and disclose annually whether the conflict minerals #1
used in their products are a source of funds for armed groups in the covered
Countries. #2#1 Conflict minerals (3TG) (regardless of place of origin): Tantalum, Tin, Tungsten,Gold#2 The Democratic Republic of Congo (DRC) and the nine adjoining countries.
The survey is also used to comply with the EU Conflict Minerals Regulation that, as ofJanuary 2021, companies importing conflict minerals into the EU as ores and raw
metals investigate and report annually whether these are related to the Organization
for Economic Co-operation and Development (OECD) Due Diligence Guidance Annex II
Risks#3 in regions defined as Conflict-Affected Areas and High-Risk Areas (CAHRAs). #4#3, #4 details on following pages

4© 2024 JEITA

1. Conflict Minerals Survey: OECD Annex II Risks
OECD Annex II Risks:Those risks defined in Annex II of the #1 OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas
OECD Annex II Risk: 1. Serious abuses associated with the extraction, transport or

trade of minerals (child labor, etc.)
2. Direct or indirect support to non-state armed groups
3. Illegal acts by public or private security forces (protection
money)
4. Bribery and fraudulent representation of the origin of minerals
5. Money laundering
6. Payment of taxes, fees and royalties due to governments (taxevasion)#1 Available for download from MOFA website (version 3, provisional translation)

https://www.mofa.go.jp/mofaj/gaiko/csr/housin.html
Please be aware that, on OECD website, the English (official) edition is updated to the current
version 3, but the Japanese translation is still of version 1 (as of June 10, 2024)
5© 2024 JEITA

1. Conflict Minerals Survey: Definition of CAHRAs in OECD

Definition of Conflict-Affected and High-Risk Areas (CAHRAs #1)
in OECD:
Conflict-affected and high-risk areas 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 consistof 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 ofnational or international law.
#1 CAHRAs: Conflict-Affected and High-Risk Areas
6© 2024 JEITA

1. Conflict Minerals Survey: CAHRAs in the EU Regulation
EU definition of CAHRAs are countries/areas that are(1) in a state of armed conflict, fragile post-conflict areas; or(2) witnessing weak or non-existing governance and security, such as failed states,
and widespread and systematic violations of international law, including humanrights abuses
The 1st version of the CAHRAs list was released on Dec.17. 2020
https://www.cahraslist.net/cahras
Release of subsequent revised lists. Egypt and Chad removed, CAHRAs’ designatedcountries/areas (Mar. 2024 ver.): 26 countries, 284 areas.

Democratic Republic of Congo, Central African Republic, Burundi, South Sudan,
Afghanistan, Yemen, India, Ukraine, Ethiopia, Eritrea, Cameroon, Colombia,
Zimbabwe, Sudan, Somalia, Turkey, Nigeria, Niger, Pakistan, Philippines,
Burkina Faso, Venezuela, Mali, Myanmar, Mozambique, Libya(countries or areas of the above)7© 2024 JEITA

1. Conflict Minerals Survey: CAHRAs in RMAP Audit
RMI#1 defines CAHRAs in RMAP Audit#2 as “Covered countries in the DFA regulation”+ “CAHRAs in EU regulation”+ “Countries/areas identified by a smelter”

EU Regulations (26)

US DFA（10）AngoraUgandaRepublic ofCongo
ZambiaTanzania
Rwanda8© 2024 JEITA

Afghanistan, Yemen, India,（Democratic Ukraine, Ethiopia, Eritrea,
Republic ofCongo）
Cameroon, Colombia,
DRC

CentralAfricanRepublic

Burundi
South
Sudan

Zimbabwe, Sudan, Somalia,
Turkey, Nigeria, Niger, Pakistan,#1 RMI:

Responsible
Minerals
Initiative

Philippines, Burkina Faso,
Venezuela, Mali, Myanmar,
Mozambique, Libya(areas of the above)#2 RMAP:

Responsible
Minerals
Assurance
Process

1. Conflict Minerals Survey: For most Japanese companies
While US unlisted companies have no information disclosure obligation under the Dodd-Frank Act,
their customers are requiring them to conduct conflict minerals surveys and report the results.
Because modern supply chains stretch worldwide, manufacturers and many other companies are
involved in these surveys.
The EU Conflict Minerals Regulation, on the other hand, targets only companies importing ores andraw metals into the EU, so fewer Japanese companies are involved. However, the EU has clearlystated in its 2023 review that if downstream companies are less responsive than importers, it will
also make reporting compulsory for downstream companies, so care must be taken in this regard.
In addition, as of January 2019, the RMAP audit protocol has changed to the 2017 version of thestandards for the minerals, risks and regions noted below. Smelters that cannot conform withthese standards cannot acquire RMAP conformant status. If a smelter in your supply chain is nolonger conformant, you may be asked by your customers to remove it from the supply chain.

9

FY2013 version

FY2017 version

Minerals

3TG (Tantalum, Tin, Tungsten, Gold）

3TG (Tantalum, Tin, Tungsten, Gold)

Risk

Source of funds for armed groupsOECD Annex II

RegionCovered countries (DRC+9)

CAHRAs© 2024 JEITA

1. Conflict Minerals Survey: RMAP
Involves huge cost and time for companies to do theirown audits of 3TG origin

Range of suppliers

Upstream①

RMAP Investigation

Mines

Smelters

Pinch Point

Audit

Refiners

Product Manufacturers

Standard

Parts
Manufacturers②
template

Down Stream

Materials
Manufactures

In-region

program

Upstream

Traders

To improve survey efficiency, the long supply chain hierarchy is
divided in 2 tiers, with smelters (“Pinch Point” #1) in the middle, as
the number of smelters are relatively small.
・ From smelters upstream, smelters are audited through the RMAP
program in the region to determine the origin of smelted
minerals・ From smelters downstream, the CMRT #2 is used to streamline
surveys.
The scheme of RMAP is scheduled to be certified in EU Regulation.
DAP#3 was developed for downstream companies in addition to RMAP.
Japanese companies may be requested by client companies to receive
DAP based audit; therefore, it is recommended that you check thecontents of DAP and implement self-assessment of your company’s
actions in advance.

Downstream#1

10© 2024 JEITA

Pinch Point is a “designated point” defined in the OECD Guidelines and mean smelters,
refiners and processors.

#2 CMRT (Conflict Minerals Reporting Template)#3 DAP (Downstream Assessment Program)1. Conflict Minerals Survey: Survey flow
Survey flow for companies downstream from smelters① Primary suppliers asked to fill in the CMRT
② CRMT survey requests move back up the supply chain③ Survey requests reach smelters
Completed CMRT submission④ Smelters submit to its direct customer/s⑤ Where necessary, companies aggregate multiple CMRTs to create theirown CMRT for submission to its direct customer/s⑥ CMRT submitted to the customer/s who originally requested the survey
Directtransaction
Original requestor(Customer)Your company

Primary supplier

Survey request

SurveyrequestSurveyrequestCollect & check11© 2024 JEITA

Nth supplier

Smelter

Surveyrequest

集計&
Aggregate& respond
回答作成
Collect & check

SubmitAggregate& respond

SubmitSubmitAggregate

・・・

Aggregate
集計&&
respond
回答作成
Collect & check

Provideinformation

Conflict Minerals Survey: RMI SSN Status
Number of Standard Smelter Names (SSN) recognized by RMI and theirconformance status (does not cover all smelters in the world)

Ｔa Tantalum ’23/05 ‘24/05
SSN total:
36
Conformant#1:
33
Conformant ratio: 92%
Active#2:
1

37
34
92%
1

Ｗ Tungsten‘23/05 ‘24/05
SSN total:
58
57
Conformant:
37
34
Conformant ratio: 64% 60%
Active:02#1 Conformant: RMAP Conformant Smelters

Ｓn Tin‘23/05 ‘24/05
SSN total:
89
91
Conformant:
63
66
Conformant ratio: 71%
73%
Active:4
5

Ａu Gold‘23/05 ‘24/05
SSN total:
178
183
Conformant:
96
90
Conformant ratio: 54%
49%
Active:57#2 Active: Smelters undergoing or scheduled for RMAP Audit12© 2024 JEITA‘23/05: as of 2023/5/11‘24/05: as of 2024/5/23

2. CMRT Rev. 6.4 Outline and Changes

13© 2024 JEITA

2 . Outline of CMRT Rev. 6.4: Structure
The CMRT comprises an 8-page Excel file

Choose language

Confirm revision

・Revision・Instruction
・Definitions
・Declaration
・Smelter List
・Checker・Product List
・Smelter Look-up※Red Letters
indicate sheets thatneed to becompleted (3 sheets)

14© 2024 JEITA

2. Outline of CMRT Rev. 6.4: Role of Each Sheet
Role of each Sheet• Revision:• Instruction:• Definitions:• Declaration:• Smelter List:• Checker:

Record of revisions
Explanation on background and how to fill in the sheets
Definitions of terminology
Company Information (Q1-8 and A-H)<REQUIRED>
List of smelters<WHERE NECESSARY#1>
Checks whether all necessary information has been filled in<CHECK REQUIRED#2 >• Product List:
List of target products< WHERE NECESSARY #3>• Smelter Look-up: List of smelters#4 （List of smelters at the time of CMRT issuance)
Notes:#1 Fill in for metals to which you responded “Yes” in Q2 of “Declaration”#2 Fill in any areas marked in red on the Checker Sheet#3 Fill in where the scope is “B: Product”#4 This is a list of smelters at the time of CMRT issuance
The latest list can be found on the RMI website※ Please read “Instructions” and “Definitions” before filling in the form.
15© 2024 JEITA

2. Changes in CMRT Rev. 6.4（2024）

Rev. 6.31（2023/5/26）⇒ Rev. 6.4（Current version 2024/4/26)
There were no major changes that would have an impact on survey
operations as follows,・Fixed the bugs and errors.
・Updated of Smelters’ information in the Smelter Look-up sheet.

16© 2024 JEITA

3. How to Complete the CMRT

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© 2024 JEITA

3. How to Complete the CMRT

3.1 Declaration Sheet- Composition -The Declaration Sheet iscomposed of three blocksⒶⒷⒶ Questions related to yourcompany’s company information(14 questions)Ⓑ Questions related to the status of your
3TG use (summary of primary supplierinformation) (8 questions)Ⓒ Questions related to yourResponsible Sourcing Procurement
policies and actions (8 questions)Ⓒ
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3. How to Complete the CMRT

3.1 Declaration SheetⒶ Company Information
All items marked with an asterisk (*) must becompleted (highlighted in yellow)
Use the pulldown menu to choose from options A to
C. The party making the report (your company)
usually decides the “Description of Scope”, but insome cases it is decided by the customer.
Note: If you intend to send the Supplier’s Declaration
Sheet to your client company, you must takeproactive measures (such as obtaining the supplier’s
permission) because sharing contact information ofindividuals stated in the Sheet may violate Private
Information Protection Law in countries that havesuch law.
DD-MMM-YYYY format
Example: 01-May-2024

A. Company:
B. Product:
C. User defined:
19© 2024 JEITA

Applies to ALL your company’s products
Applies only to SOME of your products→ Fill in the Product List Sheet (see next page)
Applies within the product scope defined by your company→ Specify the product scope in the “Description of Scope” field3. How to Complete the CMRT

3.1 Declaration SheetⒶ Company Information

If you choose B. Product (or List of Products), the line “Go to Product List
tab to enter products this declaration applies to” will appear as below, alongwith a “Click here…” instruction under “B. Product”

Clicking as instructed will take you to the Product List Sheet. Please fill in a
number recognizable by both the customer and supplier (e.g. a number specified
in the exchanged purchase/delivery specification) or product name20

© 2024 JEITA

3. How to Complete the CMRT

3.1 Declaration SheetⒷ 3TG Use Status

For each question, choose the pulldown for each 3TG, and enter your answer.
You do not need to answer for any metal for which you answered “No” to Q1.
If you answered “Yes” to Q1 but “No” to Q2, you don’t need to answer from Q3 onward.
1) Is any 3TG intentionally added or used in the
product(s) or in the production process?

2) Does any 3TG remain in the product(s)?
3) Do any of the smelters in your supply chain source
the 3TG from the covered countries?
4) Do any of the smelters in your supply chain source
the 3TG from conflict-affected and high-risk areas?
5) Does 100 percent of the 3TG (necessary to thefunctionality or production of your products) originate
from recycled or scrap sources?
6) What percentage of relevant suppliers have provided
a response to your supply chain survey?
7) Have you identified all of the smelters supplying the
3TG to your supply chain?
8) Has all applicable smelter information received byyour company been reported in this declaration?
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3. How to Complete the CMRT

3.1 Declaration SheetⒷ 3TG Use Status

1) Is any 3TG intentionally added or used in the product(s) or in the production process?
Yes: Answer “Yes” if you intentionally add or use a 3TG because it is necessary to the functionality or
production of a product, regardless of the amount.
No: Answer “No” if you do NOT intentionally add or use a 3TG, even if products include trace-level 3TG
contaminants.
※ If even one of the suppliers from which you have received a CMRT answers “Yes” in relation to
any of the 3TGs, your answer here must also be “Yes.”※ If you answered “No,” no further answers are necessary as of Q2 (option grayed out).
Examples of metals necessary to the functionality or specifications of a product:
・ Products assembled from parts using gold or tungsten alloys
・ Tin used as a coating or synthetic resin additive
・ Stannane (a tin compound) used as a glass coating agent
Examples of metals necessary to production process:・ Stannane used as a catalyst
・ Float glass tin
・ Tantalum compounds, etc., used as welding rods
Exclusions:
・ Production equipment is excluded because no 3TGs remain in the finished product. Tungsten carbide
blades and drill bits used for cutting are production equipment and are therefore excluded.
・ Packaging materials are not used as products by final customers and are therefore excluded.
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3. How to Complete the CMRT

3.1 Declaration SheetⒷ 3TG Use Status

2) Does any 3TG remain in the product(s)?
Yes: If the 3TG remains in the product
No: If the 3TG does not remain in the product※ If even one of the suppliers from which you have received a CMRT answers“Yes” in relation to any of the 3TGs, your answer here must also be “Yes.”※ If you answered “Yes”, you must fill in the Smelter List Sheet.
※ If you answered “No”, no further answers are necessary from Q3 onward(option grayed out).
If a 3TG is added because it is necessary to the functionality or specifications ofa product, it will obviously remain in the product, so you should answer “Yes”.
If 3TGs such as tin used as a catalyst in the production process, float glass tin,
and tantalum used as welding rod, remain in the product, the answer should be“Yes”.

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3. How to Complete the CMRT

3.1 Declaration SheetⒷ 3TG Use Status

3) Do any of the smelters in your supply chain source the 3TG from the covered
countries?
Yes:
If any of the smelters in your supply chain sources from Covered Countries
No:
If none of the smelters in your supply chain sources from Covered Countries
Unknown: If it is unclear whether smelters in your supply chain source from Covered Countries※ If even one of the suppliers from which you have received a CMRT answers “Yes” in relation to any of
the 3TGs, your answer here must also be “Yes”.
On the other hand, even if all CMRT answers that you receive are “No”, if “not all smelters are identifiable(if your answer in Q7 is “No”)”, your answer here must be “Unknown.”
If you answer “Yes”, you must substantiate this in the Comments field. For example, if you know thesmelter name or CID number, this can be used to determine the smelter’s third-party certification status.
If you also know the country of origin, an RCOI (Reasonable Country of Origin Inquiry) can be undertaken.
If you receive an CMRT with a “Yes” answer to Question 3 with no substantiation in the Comments field,
please ask for specific information to be added.

ExamplesMust becompleted24© 2024 JEITA

3. How to Complete the CMRT

3.1 Declaration SheetⒷ 3TG Use Status

4) Do any of the smelters in your supply chain source the 3TG fromconflict-affected and high-risk areas (CAHRAs)?
Yes: If even one of the suppliers from which you have received a CMRT sources from the
CAHRAsThe RMI stipulates that CAHRAs shall include the covered countries defined in DFA, so if
you answered “Yes” to Question 3, you should also answer “Yes” to this Question 4.
No: If none of the smelters in your supply chain source from CAHRAs
Unknown: If it is unclear whether they source from CAHRAs※ If even one of the suppliers from which you have received a CMRT answers “Yes” inrelation to any of the 3TGs, your answer here must also be “Yes.”
On the other hand, even if all CMRT answers that you receive are “No”, if “not all smelters
are identifiable (if your answer in Q7 is “No”)”, your answer here must be “Unknown”.
「If you answer “Yes”, as in Q3, you must substantiate this in the Comments field.
For example, if you know the smelter name and CID number, this can be used todetermine the smelter’s third-party certification status. If you also know the countryof origin, an RCOI (Reasonable Country of Origin Inquiry) can be undertaken.
If you have received a CMRT with a “Yes” answer to Question 4 with nosubstantiation in the Comments field, please ask for specific information to be added.
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3. How to Complete the CMRT

3.1 Declaration SheetⒷ 3TG Use Status

5) Does 100 percent of the 3TG (necessary to the functionality or
production of your products) originate from recycled or scrap sources?
Yes:
No:
Unknown:

If 100% of the 3TG comes from recycled or scrap sources
If some of the 3TG comes from natural (mined) resources
Unclear whether 100% of the 3TG comes from recycled or
scrap sources※ If even one of the suppliers from which you have received a CMRT answers“No” in relation to any of the 3TGs, your answer here must also be “No”.
Only if answers in all CMRTs are “Yes,” your answer will be “Yes”.

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3. How to Complete the CMRT

3.1 Declaration SheetⒷ 3TG Use Status

6) What percentage of relevant suppliers have provided a response to your supply chain
survey?
Choose one of the following options according to the percentage of answers received fromsuppliers subject to the survey. What percentage of relevant suppliers have provided a response to
your supply chain survey?
-

100％:
Greater than 90%:
Greater than 75%:
Greater than 50%:
50% or less:
None:

Receive answer from all suppliers
Receive answer from more than 90% of suppliers
Receive answer from more than 75% of suppliers
Receive answer from more than 50％ of suppliers
Receive answer from 50% or less of suppliers
Receives no answer from suppliers※ Unrelated to the contents of the answer to Question 6 received from suppliers

Suppliers excluded from the scope of the CMRT:• Suppliers of equipment, tools, consumables, and other products outside thescope of the CMRT• Suppliers of parts and materials which clearly do not contain 3TGs
Note: Surveys must be continued until the response rate is 100%.
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3. How to Complete the CMRT

3.1 Declaration SheetⒷ 3TG Use Status7) Have you identified all of the smelters supplying the 3TG to your supply chain?
Yes:
No:

If you have identified all of these smelters
If you have not identified even one smelter supplying the 3TG to your supply chain

You can only answer “Yes” if you meet all four of the conditions below:① You have received CMRTs from all the relevant suppliers(=your answer to Q6 was 100%).
② The answer to Q6 in all the CMRTs you received was 100%.
③ The answer to Q7 in all the CMRTs you received was “Yes”.
④ The answer to Q8 in all the CMRTs you received was “Yes”.

※ If you answered “No” to this question (i.e., you have not identified all of
the relevant smelters), you may be asked by customers to work toward
being able to give a “Yes” answer, and to give a timeframe for that.

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3. How to Complete the CMRT

3.1 Declaration SheetⒷ 3TG Use Status8) Has all applicable smelter information received by your company beenreported in this declaration?
Yes:

No:

You have reported all applicable smelter information received by yourcompany
You have not reported some of the applicable smelter information received
by your company※ Unrelated to the contents of the answer to Question 8 received from suppliers

The answer will usually be “Yes,” but it may be “No” if you have notreported all applicable information due to reasons such as yourconfidentiality obligation to a supplier.

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3. How to Complete the CMRT

3.1 Declaration SheetⒸ Policies and Actions

Choose the pulldown to answer each of the 8 questions on your company’s policies andactions in relation to responsible minerals sourcing.
A. Have you established a responsible minerals sourcing policy?
B. Is your responsible minerals sourcing policy publicly available on
your website?
C. Do you require your direct suppliers to source the 3TG fromsmelters whose due diligence practices have been validated by anindependent third party audit program?
D. Have you implemented due diligence measures for responsible
sourcing?
E. Does your company conduct conflict minerals survey(s) of yourrelevant supplier(s)?
F. Do you review due diligence information received from yoursuppliers against your company’s expectations?
G. Does your review process include corrective action management?
H. Is your company required to file an annual conflict minerals
disclosure“Unrelated to the contents of CMRTs received from suppliers”
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3. How to Complete the CMRT

3.1 Declaration SheetⒸ Policies and Actions

A. Have you established a responsible minerals sourcing policy?
Yes:
No:

If your company has established a responsible minerals sourcing policy
If your company has NOT established a responsible minerals sourcing policy
To answer “Yes”, your responsible minerals sourcing policy must cover all the elements
below and at a minimum include those items in brackets* Metals covered (3TG)* Risk covered (OECD Annex II risk)* Regions covered (CAHRAs)* Response when a risk is identified※ The above policy regarding 3TGs is sufficient for DFA and EU Regulations, however, taking into consideration
the expansion of target minerals and risks, it is preferable to refer also to matters such as influence on theenvironment.
The above policy does not necessarily have to be a independent “Responsible Minerals Sourcing Policy”;
a “Responsible Sourcing Policy” that includes the above items written in red is sufficient.

B. Is your responsible minerals sourcing policy publicly available on your website?
(Note – If “Yes”, the user shall specify the URL in the Comments field.)
Yes:
No:

31

© 2024 JEITA

If your responsible minerals sourcing policy is publicly available on your website
If you have no website or your responsible minerals sourcing policy is notposted on your website

3. How to Complete the CMRT

3.1 Declaration SheetⒸ Policies and Actions

C. Do you require your direct suppliers to source the 3TG from smelters whose due
diligence practices have been validated by an independent third party audit program?
Yes: If, in the form of your company’s policies, a written sourcing request, or an e-mailrequest, etc., you require your direct suppliers to source from smelters whose due
diligence practices have been validated by an independent third-party audit program#1
No: If you do not require this from or clearly indicate this to your direct (primary)
suppliers.
#1 Independent third-party audit programs include the following:

London Bullion Market Association (LBMA), Responsible Jewellery Council (RJC)
Some customers press for “all smelters in the supply chain to be RMAP conformant” andstrongly urge for “any smelters that fail to do so to be removed from the supply chain”.
If the CMRTs you receive from suppliers note non-RMAP conformant smelters, werecommend going through the supply chain to notify these smelters of the above and urge
them to acquire conformant status.
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3. How to Complete the CMRT

3.1 Declaration SheetⒸ Policies and Actions

D. Have you implemented due diligence measures for responsible sourcing?
Yes:
No:

If you have implemented due diligence#1 measures such as the examples below
If you have not implemented due diligence measures

Examples of measures:・ Highlighting and assessing risks from CMRTs received from suppliers⇒ e.g. Ranking the rates of receipt of CMRTs and the precision of smelter list
information, etc.
・ Creating and implementing strategies for dealing with identified risks⇒ e.g. Determining and implementing action rules based on the status of responses
to Questions A-H.
・ Prior written confirmation and agreement with suppliers on actions that will be taken
when a connection with armed groups is identified.
#1 due diligence = Risk assessment

Activities to make the supply chain transparent, check for any risks such as humanright abuse in the origin of raw material, and correct any problems that are found.
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3. How to Complete the CMRT

3.1 Declaration SheetⒸ Policies and Actions

E. Does your company conduct Conflict Minerals survey(s) of your relevant
supplier(s)?
Yes (IPC-1755) #1 : If you conduct conflict minerals surveys of your relevant
suppliers using the CMRT format
Yes (other format):If you conduct conflict minerals surveys of your relevant
suppliers in a format other than the CMRT (describe suchformat in the Comments field)
No: If you do not collect conflict minerals due diligence informationfrom your suppliers#1 IPC-1755:

34© 2024 JEITA

A standard establishing the requirements for exchanging data between
suppliers and their customers in regard to the responsible sourcing ofminerals, and establishing the requirements of the 3TG, cobalt andmica survey

3. How to Complete the CMRT

3.1 Declaration SheetⒸ Policies and Actions

F. Do you review due diligence information received from your suppliers against yourcompany’s expectations?
Yes: If you have a process for reviewing CMRTs (DD information) received from suppliers
No: If you do not review CMRTs (DD information) received from suppliers
Review process examples:
・ Review the accuracy and completeness of supplier CMRTs.
・ Review whether suppliers have a responsible minerals sourcing policy, or review theiractions based on their responses to Questions C-H.
・ Assess the certification status of smelters on the Smelter List.
✓ Point:
It is important not just to collect supplier responses but to check the content of the
responses received. If you think there are any risks, you should go back up the supply
chain or use the Internet to check this.
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3. How to Complete the CMRT

3.1 Declaration SheetⒸ Policies and Actions

G. Does your review process include corrective action management?
Yes:

If you have the kind of corrective action management process noted belowNo:

If you don’t have a corrective action management process
Examples of corrective action management:
・ If a supplier does not have a responsible minerals sourcing policy,
encouraging them to develop one.
・ If a smelter on the Smelter List is not RMAP-conformant, go up
the supply chain to encourage them to undergo an RMAP audit.
・ If a supplier scores poorly in your CMRT review process as notedin Question F, ask the supplier to address those issues.

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3. How to Complete the CMRT

3.1 Declaration SheetⒸ Policies and Actions

H. Is your company required to file an annual conflict minerals disclosure?
Yes, with the SEC: If you are listed on the SEC (US Securities andExchange Commission)
Yes, with the EU: If your company falls within the scope of the
EU Conflict Mineral Regulation
Yes, with the SEC and EU: If you are required to report to both the SEC
and the EU
No: If you are required to report to neither

Most Japanese companies will answer “No” to this question.

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3. How to Complete the CMRT

3.2 Smelter List Sheet– Structure -On the Smelter List, you enter information on all smelters in your supply chain.
The sheet comprises 17 items.

1

2

3

4

5

6

7

8

9

1. Smelter Identification Number Input Field
2. Metal (*)
3. Smelter Look-Up (*)
4. Smelter Name (1)5. Smelter Country (*)
6. Smelter Identification Number
7. Source of Smelter Identification Number
8. Smelter Street
9. Smelter City（*） Compulsory fields
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10

11

12

13

14

15

16

17

10. Smelter Facility Location: State / Province
11. Smelter Contact Name
12. Smelter Contact Email13. Proposed next steps
14. Name of Mine(s) or if recycled or scrap
sourced, enter "recycled" or "scrap"
15. Location (Country) of Mine(s) or if recycled
or scrap sourced, enter "recycled" or "scrap"
16. Does 100% of the smelter’s feedstock
originate from recycled or scrap sources?
17. Comments

3. How to Complete the CMRT

3.2 Smelter List Sheet- Structure -Before filling in the Smelter List, please make the following preparations:✓ List all the smelters that are listed in all CMRTs that you received✓ Use CID numbers, etc., to remove duplications (name identification)✓ If your list contains non-SSN smelters without CID numbers, check on their website, etc., to confirm
whether they really are operating smelters (due diligence)✓ Delete trading companies and other businesses which are clearly not smelters
In some cases, smelters that were SSNs may have become non-SSNs. For example, they may have:• Ceased to operate as a smelter• Amalgamated with another smelter• Been discovered not to be a smelter
The SSNs listed on the Smelter Look-up Sheet are SSNs at the time of CMRT issuance#1, and there aresome cases where RMI subsequently recognizes a smelter as an SSN and gives it a CID number (you cancheck this on the RMI website). #1 In CMRT Rev.6.4, SSNs as of Feb. 28, 2024 are listed
Even in these cases, for the purposes of this CMRT, the smelter will be deemed “Smelter not listed.”
Glossary of Frequently Used Terms
CID: An ID assigned to identify a company as a “company that RMI is aware that it is reported as a smelter”. However, it may notnecessarily be a “smelter”.
SSN: An abbreviation for Standard Smelter Names. A company that RMI determines “as a smelter” from its survey. The SSN List may be
confirmed at the RMI HP. “SSN” is not equal to “Conformant”.
Conformant Facilities List: A list of SSN companies that passed (are conformant to) the RMAP Audit (including those that passed themutual certification system).
Active Facilities List: List of companies that RMI acknowledges as undergoing or preparing to undergo a RMAP.
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3. How to Complete the CMRT

3.2 Smelter List Sheet- Data Entry -① If you already know the CID number
When you enter the CID number into Field A, Fields B, C, E, F, G, I, and J will be automatically populated.
We recommend copying and pasting CID numbers into Field A.

Enter the CID number in Field A

Fields B, C, E, F, G, I, and J will be populated automatically✓ When entering a CID number, columns B and C may appear in red.
Smelters that are displayed in red are those for which "No" was selected in 1) or 2) of the following
questions on the Declaration Sheet.
1) Is 3TG intentionally added or used in the product itself or in the manufacturing process?
2) Does 3TG remain in the product?
If it is displayed in red, please make sure that you have selected the correct mineral and smelter.
e.g. Gold content is set to "No" on the
Declaration sheet, but the gold smelter CID
number is entered on the Smelter List, so it
is displayed in red (and vice versa).
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3. How to Complete the CMRT

3.2 Smelter List Sheet- Data Entry -② If you don’t know the CID number
If you select a metal in Field B and chose the appropriate smelter name in Field C, Fields E, F, G, I, and J
will be populated automatically.
You can copy and paste data into Fields B and C, but if the data in Field C does not exactly match thedata in the Smelter Look-up field on the Smelter Look-up Sheet, Fields E, F, G, I, and J will not be
populated automatically even if it is a SSN (such smelter has a CID number).
③ If there are no selection options in Field C (non-SSN smelter)
Once you have selected the metal in Field B, select “Smelter not listed” in Field C, and enter the smeltername in Field D and the smelter country in Field E. All these fields are compulsory, but please also
enter data in Fields H-P to the best of your ability.
④ If there are any Smelters that the name or location is not identified
Select the metal in Field B and chose “Smelter not yet identified” in Field C.
⑤ If a mineral is selected in column B, and then columns B and C are displayed in red
Please check again because the mineral selected is different from the mineral specified as contained in
the Declaration sheet.

②
③
④
⑤
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3. How to Complete the CMRT

3.3 Product List Sheet- Data Entry -If your Declaration Scope or Class is “B. Product (or List of Products)”, youmust complete the Product List.

Manufacturer’s Product Number (compulsory): Enter a number recognizable by both the customer
and supplier (e.g. a number specified in theexchanged purchase/delivery specification)
Manufacturer’s Product Name:
Comments:

42© 2024 JEITAEnter a product name recognizable by boththe customer and supplierEnter where necessary3. How to Complete the CMRT

3.4 Checker Sheet

After completing the Declaration Sheet, Smelter List Sheet, and Product List Sheet,please use the Checker Sheet to check that you have populated all the necessary fields.
③

Complete→②
Incomplete→①① Select Checker Sheet to confirm your data entry.
② Areas in green are complete; areas in red are incomplete.
③ When the “Required fields remaining to be completed” value is “0”,your data entry is complete.
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Ref: RMAP status terminology
RMAP (Responsible Minerals Assurance Process)StatusConformant

www.responsiblemineralsinitiative.org/members/database-field-definitions/
Description
Further description
Audited and found conformant with the relevant
RMAP Conformant Smelters
RMAP standard

ECAP

Extended Corrective Action Plan

ActiveEngaged in the program but not yet conformant

Smelters that are currently non-conformant, but havecommitted to address outstanding issues
Smelters that are undergoing or have committed toundergo a RMAP Audit
Smelters that have initiated communications toward
participating in a RMAP Audit

Not yet active but in communication with RMAP
and/or member company
Outreach needed by RMI member companies to
Smelters not yet “In Communication” and need
Outreach Required contact entity and encourage their participation in
encouragement to participate in a RMAP Audit
RMAP audit
Audited but found not conformant with the relevant
Non-Conformant
RMAP Non-Conformant Smelters
RMAP standard
Meets the definition of a smelter / refiner; included in Meets the definition of Smelters and is included in CMRT
Eligible
the CMRT Standard Smelter List
Standard Smelter List
Not ApplicableNot eligible for the RMAP
Not eligible for the RMAP Audit (is not a smelter)
In Communication

Audit(Assessment) Indicates the time period from the last audit date toCycle
the next planned re-audit date.
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The time period from the last audit date to the nextplanned re-audit date:
1 year: Standard audit period for RMAP smelters
3 years: Audit period for smelters in a risk-based audit
program and TI-CMC members#1#1TI-CMC：Tungsten Industry Conflict Minerals Council

Ref: Conflict Mineral Survey Abbreviations (2024)
Abbreviation
Category
3TG
Survey Related
ASM
Organization
CAHRAsName of Country/Area
CCCMC
Organization
CI
Organization
CMRT
Survey Related
CRT
Survey Related
DD
Survey Related
DFA
Law
DRC
Name of Country/Area
ECAPSurvey Related
EMRT
Survey Related
GeSI
Organization
IPC
Organization
iTSCi
Organization
ITU
Organization
JEITA
Organization
LBMA
Organization
LME
Organization
LSM
Organization
MRT
Survey RelatedOECD
Organization
OFAC
Organization
PRT
Survey Related
RBA
Organization
RCI
Organization
RCOI
Survey Related
RJC
Organization
RMAP
Survey Related
RMI
Organization
RMI
Organization
RRA
Survey Related
SDGs
OthersSEC
Organization
SOR
Survey Related
SSN
Survey Related

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Description
Tantalum, Tin, Tungsten, Gold
Artisanal and Small-scale Mining
Conflict-Affected High-Risk Areas
China Chamber of Commerce for Importers & Exporters for Minerals, Metals & Chemicals
Coblat Institute
Conflict Minerals Reporting Template
Cobalt Reporting Template
Due DiligenceDodd-Frank Wall Street Reform and Consumer Protection Act
Democratic Repulic of the Congo
Extended Corrective Action Plan
Extended Mineral Reporting Template
Global e-Sustanability Initiative
Association Connecting Electronics Industries
IRTI Tin Supply Chain Initiative
International Telecommunication Union
Japan Electronics and Information Technology Industries Association
London Bullion Market Association
The London Metal Exchange
Large-Scale Mining
Mica Reporting Template
Organisation for Economic Co-operation and Development
Office of Foreign Assets Control
Pilot Reporting Template
Responsible Business Alliance
Responsible Cobalt Initiative
Responsible Country of Origin Inquiry
The Responsible Jewellery Council
Responsible Minerals Assurance Process
Responsible Minerals Initiative
Responsible Mica Initiative
Risk Readiness Assessment (by RBA)
Sustainable Development Goals
U.S. Securities and Exchange Commision
Smelter or RefinerStandard Smelter Name

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