Generic Technology, Communication & Online - Labour Policy Question 29

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Question

Does the brand (company) have a policy to exclude smelters that use conflict mineral, and has at least started with mapping the origin of the minerals being used in its hardware appliances?

  • Dutch version: Heeft het merk (bedrijf) een beleid om smelters van conlifct mineralen uit te sluiten, en is het tenminste begonnen met het uitzoeken van de herkomst van de mineralen?
  • German version: Setzt der Markenhersteller Maßnahmen um welche die Beschaffung von Konfliktmineralien ausschließen? Wurde in jedem Fall mit der Analyse begonnen, woher die verarbeiteten Mineralien bezogen werden?

References and Guidelines

This question relates to O4 of Greenpeace’s Guide to Greener Electronics. Most electronics cannot be made without minerals like tin, tantalum, tungsten (the 3 Ts) and gold, which are often sourced from areas with ongoing armed conflicts, like eastern Congo. In these areas, many minerals are mined either by the national government or one of several armed militias and rebel groups under conditions of serious human rights abuses and without concern for environmental protection. Therefore, the mined minerals are called “conflict materials”. According to Greenpeace the social and environmental dangers around sourcing these conflict materials are growing.


The minerals most likely to be “conflict materials” are:

  • Tin (used as a solder on circuit boards in all electronic devices)
  • Tantalum (stores electricity and is essential to portable electronics and high speed processing devices)
  • Tungsten (enables cell phone vibration alerts and is in LCD screens)
  • Gold (used in wiring of electronic devices)


Brands can (1) publish their own policy that specifically excludes smelters of conflict minerals or state that they (2) implement the EICC-program and/or the OECD Guidelines or that they (3) require suppliers to either participate in the program or adhere to the guidelines.


The EICC conflict-free smelter program, set up by the EICC and GeSi (Global e-Sustainability), makes use of an independent third party that evaluates smelter’s procurement activities and determines whether the smelter has demonstrated that all the minerals it processes originate from conflict-free sources. For now there’s only a published list of tantalum smelters available, see here. The OECD guidelines (called the ‘Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas’) determine whether smelters that do source from the Democratic Republic of the Congo (or adjoining countries) respect human rights and avoid contributing to conflict through their mineral or metal purchasing decisions and practices. Companies can commit to the Due Diligence Guidance by implementing them and conforming to them.


Please note: Supporting the EICC-Program or the OECD-Guidelines is not sufficient for a ‘Yes’. Brands should implement the program or the guidelines. Please note: Encouraging suppliers to follow the EICC-Program or the OECD-Guidelines is not sufficient for a ‘Yes’. Brands should oblige their suppliers to follow the program or the guidelines. Please note: Stating only to purchase conflict minerals from EICC audited supplier is not sufficient for a ‘yes’, because at the moment (February 2012) the program has only audited tantalum suppliers. Please note that this issue is in its beginning phase and is changing. At this moment it is not possible yet to ensure that all minerals come from conflict-free sources (eg EICC does not yet publish lists of audited tin, tungsten and gold suppliers). That’s why for now we only ask for a policy. We may change this question in the future when an established auditing process is in place.