Skip to main content
Governance Authority
Category: Third-Party and Supply Chain

Conflict Minerals

Also known as: 3TG, 3TGs, 3TG minerals
Simply put

Conflict minerals are natural resources mined in conflict-affected areas where their sale can help fund armed groups, violence, or forced labor. The term most commonly refers to tantalum, tin, tungsten, and gold, often abbreviated as 3TGs, which can end up in everyday products such as electronics, vehicles, and jewelry. Companies may face expectations or requirements to check whether these materials appear in their supply chains.

Formal definition

"Conflict minerals" is a term generally used to describe minerals sourced from conflict-affected locations whose extraction or trade may finance or benefit armed conflict, violence, or associated abuses such as forced labor. As defined under certain US legislation, the term currently refers to the metals tantalum, tin, tungsten, and gold (the "3TGs"), which are derived from mineral precursors and can be incorporated into a wide range of manufactured goods. The specific scope, covered minerals, and applicable due diligence or reporting obligations vary by regime and jurisdiction; for example, the framing under US legislation and under the EU Conflict Minerals Regulation differ in structure and coverage. This entry is educational and does not identify the precise legal obligations, covered entities, or reporting mechanics of any particular statute or regulation, which depend on the applicable regime and the facts of a given supply chain.

Why it matters

Conflict minerals sit at the intersection of supply chain compliance, human rights, and reputational risk. Because tantalum, tin, tungsten, and gold (the 3TGs) can be sourced from conflict-affected areas where their trade may help finance armed groups, violence, or forced labor, companies that use these materials face pressure to understand and account for their sourcing. These metals are found in small quantities across a wide range of manufactured goods, including electronics, mobile phones, vehicles, and jewelry, which means the issue reaches far beyond mining and extractive companies into general manufacturing and consumer products.

The compliance dimension is significant because the applicable expectations and obligations vary by regime and jurisdiction. US legislation and the EU Conflict Minerals Regulation, for example, differ in structure and coverage, so an entity's specific responsibilities depend on where it operates, what it produces, and how its supply chain is organized. Some obligations are legal requirements for covered entities, while other expectations arise from voluntary standards, customer demands, or investor and stakeholder scrutiny. Determining which apply requires facts about the business and jurisdiction-specific legal analysis.

Beyond formal requirements, conflict minerals carry reputational and ethical stakes. Association with supply chains that fund violence or forced labor can damage a company's standing with customers, investors, and the public, even where a specific legal obligation may not clearly apply. This makes supply chain visibility a matter of both compliance and broader risk management. This entry is educational and does not identify the precise legal obligations, covered entities, or reporting mechanics of any particular statute or regulation.

Who it's relevant to

Chief Compliance Officers
Compliance functions typically own the design and operation of supply chain due diligence and any reporting processes tied to conflict minerals. Their focus includes identifying which regimes apply to the organization, coordinating supplier inquiries, and maintaining documentation. The specific obligations depend on the applicable jurisdiction and the facts of the supply chain.
General Counsel
Legal teams assess whether and how particular conflict minerals requirements apply to the entity, given that US legislation and the EU Conflict Minerals Regulation differ in structure and coverage. They help distinguish binding legal obligations from voluntary standards and stakeholder expectations, and interpret how requirements apply to the organization's products and jurisdictions.
Procurement and Supply Chain Managers
Because 3TGs are incorporated into components upstream, operational supply chain and procurement teams are central to tracing materials and gathering sourcing information from suppliers. They generally execute the inquiries that feed into compliance and reporting processes, working within the framework set by legal and compliance functions.
Boards and Audit or Risk Committees
Directors and relevant committees exercise oversight of the risks that conflict minerals present, including compliance, reputational, and ethical dimensions. Their role is generally oversight rather than day-to-day execution: satisfying themselves that management has appropriate processes in place, rather than performing the tracing or reporting activities themselves.
Internal Audit and Assurance Functions
Assurance functions may evaluate whether conflict minerals due diligence processes are designed appropriately and operating effectively. Their independence from the management activities they review is what distinguishes their role from that of compliance and procurement, who own and perform the underlying processes.

Inside 3TG

Designated Minerals (3TG)
Conflict minerals commonly refers to a specific set of minerals and their derivatives, generally tin, tantalum, tungsten, and gold, often abbreviated as 3TG. The precise scope of covered minerals depends on the applicable regime and may differ across jurisdictions.
Covered Sourcing Geographies
Regimes typically focus on minerals originating from conflict-affected and high-risk areas, such as designated regions where mineral trade may finance armed conflict. The defined geographic scope varies by framework and can change over time.
Supply Chain Due Diligence
A core element is a due diligence process to identify the source and chain of custody of covered minerals. Many programs reference internationally recognized due diligence guidance for responsible mineral supply chains, though the specific standards applied depend on the entity and its regulatory obligations.
Disclosure and Reporting Obligations
Certain jurisdictions impose disclosure requirements on in-scope companies, which may include describing sourcing, due diligence measures, and findings. Whether an obligation is binding, and its exact content, depends on the applicable statute, regulation, or listing rule and the entity type.
Applicability Thresholds
Requirements generally apply only to entities that meet specified criteria, such as manufacturing or contracting to manufacture products in which covered minerals are necessary to functionality or production. Whether a given company is in scope is a fact-specific and jurisdiction-specific determination.
Accountability Across the Program
Management typically owns the operational activities of supply chain due diligence, data collection, and preparation of any required disclosures. The board or a designated committee generally exercises oversight of the program and related reporting, while assurance functions may provide independent evaluation where engaged.

Common questions

Answers to the questions practitioners most commonly ask about 3TG.

Does the conflict minerals rule ban companies from sourcing tin, tungsten, tantalum, or gold from the Democratic Republic of the Congo and adjoining countries?
Generally, no. The relevant regime is typically a disclosure and due diligence obligation rather than a prohibition. It commonly requires certain issuers to determine whether specified minerals originate in the covered region and to report on their supply chain due diligence, but it usually does not forbid sourcing from those countries. Whether and how a company chooses to source responsibly from the region is a business and compliance decision informed by due diligence, and the specifics depend on the applicable rules and the entity's circumstances. This entry is educational and not legal or compliance advice.
Is a conflict minerals compliance program purely a legal filing task owned by the disclosure or SEC-reporting function?
Not typically. While reporting obligations may be triggered by securities disclosure requirements in some jurisdictions, the underlying work generally spans procurement, supply chain management, compliance, and internal audit or assurance. Management ordinarily owns the design and operation of the due diligence process and controls, while the board or a relevant committee may exercise oversight. Treating it solely as a filing exercise can overlook the operational sourcing, supplier engagement, and control activities that support any resulting disclosure. Roles and accountability depend on the entity's structure and applicable framework.
How does a company determine whether it is within the scope of a conflict minerals obligation?
Scoping typically begins by assessing whether the entity is the type of reporting company covered by the applicable rule and whether the specified minerals are necessary to the functionality or production of a product it manufactures or contracts to manufacture. This is generally a facts-and-circumstances analysis that varies by jurisdiction, sector, and product line. Companies often document their scoping determination and the reasoning behind it. Because coverage thresholds and definitions differ across regimes, entities should confirm applicability against the specific rules that apply to them and, where needed, seek professional advice.
What kind of supply chain due diligence is generally expected under conflict minerals regimes?
Many regimes reference or align with internationally recognized due diligence frameworks that describe a risk-based, step-wise approach: establishing management systems, identifying and assessing supply chain risks, designing and implementing a response strategy, supporting independent audit at relevant points in the chain, and reporting. The intensity of effort is typically proportionate to the identified risk. Exact expectations vary by framework and jurisdiction, and companies commonly tailor their approach to their supply chain complexity. Design and operating effectiveness of these processes are distinct considerations that may warrant separate evaluation.
How can a company obtain reliable information from suppliers about mineral origin?
Common practices include incorporating conflict minerals requirements into supplier contracts and codes of conduct, using standardized industry survey templates to collect smelter and refiner information, and engaging suppliers to improve response quality over time. Because most companies are far removed from the mine level, due diligence generally focuses on tracing back to smelters or refiners and relying, where available, on independent assurance or industry validation programs. Data completeness and reliability are often persistent challenges, and companies typically document the steps taken and any limitations encountered.
What is the role of internal audit or assurance in a conflict minerals program?
Assurance functions generally provide independent evaluation of whether the due diligence process is designed appropriately and operating effectively, rather than owning the process itself, which typically sits with management. Depending on the applicable regime, an independent audit of some part of the due diligence or a related report may be required or referenced, and the nature and scope of any such audit vary. Internal audit may also assess control design and operating effectiveness, data quality, and completeness of supplier outreach. The specific assurance expectations depend on the governing rules and the entity's own risk assessment.

Common misconceptions

Conflict minerals rules ban companies from sourcing 3TG from conflict-affected regions.
Many regimes are generally oriented toward due diligence and disclosure rather than an outright prohibition on sourcing. The emphasis is typically on identifying, assessing, and reporting on sourcing risks. The precise obligations depend on the applicable jurisdiction and framework.
Conflict minerals obligations are the same worldwide and apply to all companies.
Requirements vary by jurisdiction, sector, and entity type, and applicability generally depends on specific thresholds such as whether covered minerals are necessary to a product. Some obligations are binding legal requirements in certain jurisdictions, while related due diligence standards may function as guidance rather than universal mandates.
Meeting conflict minerals requirements is solely a procurement task, and the board has no role.
Sourcing due diligence and data gathering are typically operational activities owned by management, but the board or a relevant committee generally holds an oversight responsibility for the compliance program and any public reporting. Oversight and operational execution are distinct roles that should not be conflated.

Best practices

Confirm applicability first by conducting a fact-specific and jurisdiction-specific assessment of whether covered minerals are within scope for the entity, rather than assuming the rules apply or do not apply.
Establish a documented supply chain due diligence process, and consider aligning it with an internationally recognized responsible sourcing framework appropriate to the entity's obligations and risk profile.
Assign clear accountability by defining which management function owns due diligence, data collection, and any required disclosures, and which board committee holds oversight of the program.
Engage suppliers systematically to obtain and validate sourcing information, and maintain records supporting the chain-of-custody inquiries and any reasonable country-of-origin determinations.
Coordinate with legal counsel to determine which obligations are binding in the relevant jurisdictions and to ensure any disclosures meet the applicable statutory, regulatory, or listing-rule content requirements.
Where appropriate, obtain independent assurance over the design and operating effectiveness of the due diligence program, and periodically report results and material findings to the board or its designated committee.