Know-your-counterparty activities do not meet the
requirements of the Standard, Section VIII.B.1.
Establish a documented Know
Your Counterparty Process that would include, at a minimum, the requirements
to determine the identity, type of business relationship and legality of
business operations for each supplier of tantalum. The KYC process shall include
verification of individuals and entities that hold direct or indirect
ownership stakes in the smelters’ counterparties against relevant Government
Ensure that all suppliers
provide complete information for the KYC Questionnaire.
Furthermore, the KYC process
shall be applied before entering into a business relationship with a supplier
and throughout the business relationship.
| 2 ||
assessment process does not meet the requirements of the Standard, Section
The process to
conduct a risk assessment should include, at a minimum, assessment of
discrepancies, plausibility, and red flags as they relate to suppliers,
material, and conflict-affected and high-risk areas.
The risk assessment process was not consistently
implemented as per Section VIII.B.3. of the Standard.
Materials sourced from CAHRAs should be considered a red
flag, therefore triggering a high-risk supply chain. The corresponding
High-Risk workbook must then be completed. Note this is does not need
to be written.
| 4 ||
There is no
process in place to mitigate risks occurring in high-risk supply chains as
per Section VIII.C. of the Standard.
processes to mitigate risks that are identified and assessed in the high-risk
supply chains. While iTSCi may identify risks, it is the smelter’s
responsibility to assess and follow up on mitigation of those risks.
See Section V.3. of the Standard. Note, these do not need to be