No Audit Does Not Equal Noncompliance

Three quick thoughts on today’s news that the world’s electronics OEMs haven’t been able to eradicate conflict minerals from their supply chains.

1. Given that OEMs have a tough time discerning where, exactly, materials came from, how is it that a third-party is so certain it knows how that supply chain is supposed to look?

2. Given the third-party’s judging criteria covered traceability and auditing, and not actual supply,we should not assume that the OEMs under review even use conflict minerals in the first place. Indeed, the Congo supplies a very small percentage of most the industry’s raw materials. Media reports on the unpublished study are not clear on either point.

3. Did anyone really think they could change a supply chain overnight?