Extended Corrective Action Plan

Finding: Non-Conformance: Potential Corrective Actions:
1   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 sanction lists.   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   The risk assessment process does not meet the requirements of the Standard, Section VIII.B.3. 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.
3 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. Develop 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 written.