If you think conflict minerals reporting is only for electronics and tech companies, think again. Steel manufacturers—especially those sourcing materials that touch tin, tungsten, tantalum, or gold (commonly known as the 3TG minerals)—are very much in the spotlight.
As a Chief Compliance Officer (CCO), your responsibility goes beyond meeting bare-minimum regulatory requirements. You need to ensure your company’s conflict minerals disclosures are accurate, timely, and transparent enough to stand up to investor, customer, and regulator scrutiny.
Why It Matters for the Steel Industry
Steel companies often work with a wide network of upstream suppliers, many of whom touch 3TG minerals during smelting, alloying, or processing. These minerals are used to improve hardness, resistance, or performance.
But here’s the challenge: 3TG minerals are sometimes sourced from regions involved in armed conflict, where mining revenue may fund violence or human rights abuses—particularly in the Democratic Republic of the Congo (DRC) and surrounding countries.
That’s why governments and major buyers demand transparency. Whether you’re directly handling these minerals or using inputs from suppliers who are, you’re part of the disclosure chain.
What Regulations Apply?
The U.S. Dodd-Frank Act’s Section 1502 is the most well-known regulation. It requires publicly traded companies to file a specialized disclosure if 3TG minerals are “necessary to the functionality or production” of their products.
Even if you’re not a U.S. public company, chances are your customers are—and they’ll ask you for conflict mineral certifications as part of their due diligence. Other regions, like the European Union, have their own regulations requiring traceability and disclosure from importers and downstream users.
Bottom line: if your steel touches 3TG, you’re expected to provide answers.
What CCOs Must Monitor Daily
Conflict minerals compliance isn’t a once-a-year filing. It’s an ongoing effort. Here’s what should be on your radar every day:
Supplier Origin Declarations: Are your raw material suppliers completing Conflict Minerals Reporting Templates (CMRTs) and are those responses current?
Smelter and Refiner Validation: Are your sources verified as conflict-free by recognized initiatives like the Responsible Minerals Initiative (RMI)?
New Product Launches: Are engineering or procurement teams flagging materials with potential 3TG exposure before they’re used?
Customer Requests: Are you ready to quickly supply traceability documentation when a customer requests it—or when you’re bidding for a new contract?
Watchlist Changes: Are you monitoring updates from conflict minerals regulatory bodies and NGOs?
Documentation Best Practices
Transparency starts with documentation. Here’s how to ensure yours is audit-ready:
Maintain a Centralized Conflict Minerals Database with all CMRTs, supplier certifications, and declarations.
Use Version Control to track changes over time and identify outdated records.
Create Audit Trails that link supplier declarations to purchase orders, batches, or production lots.
Conduct Gap Analysis to identify where supplier disclosures are missing, incomplete, or non-conforming.
When to Escalate
Not all suppliers will be responsive—and some may provide ambiguous data. As a CCO, you must know when to escalate:
If a supplier is sourcing from a red-flag region and cannot verify smelter data.
If a customer flags your company for insufficient disclosures.
If your own internal review reveals a product line with unknown mineral content.
Escalation doesn’t mean dropping the supplier overnight—but it may involve setting a corrective action plan, issuing warnings, or involving legal counsel.
Technology Can Help
Manual tracking is time-consuming and error-prone. Conflict minerals compliance platforms can:
Automate CMRT collection and validation
Compare smelter lists against official conflict-free databases
Generate compliance dashboards for executive visibility
Provide alerts when certifications are expiring or incomplete
These tools are especially useful during supplier onboarding and annual reporting periods.
Beyond Compliance: Why This Is a Strategic Issue
Conflict minerals reporting isn’t just about ticking boxes. It’s about:
Protecting brand reputation: ESG-minded investors and customers want ethical sourcing
Winning more business: Conflict-free sourcing can be a competitive advantage
Avoiding legal risk: Inaccurate disclosures can lead to SEC investigations, customer audits, or reputational damage
It also aligns with broader ESG goals. CCOs who take a proactive approach to conflict minerals often find they’re also improving supplier relationships, increasing transparency, and building a culture of responsible sourcing.
Final Thought: Don’t Wait for the Request
Too many companies scramble to collect conflict minerals data only when a customer or auditor demands it. That’s risky—and completely avoidable.
As a steel CCO, you should already have systems and data in place to respond confidently. Conflict minerals reporting isn’t going away. In fact, it’s becoming more important every year.
Get ahead of it. Monitor it daily. And show your customers, regulators, and investors that your company takes sourcing seriously—because compliance isn’t just good policy. It’s good business.
