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Some of the top problems facing your company may include

  • your customer base wants you to be climate neutral but you don't know how
  • regulators want you to report and evidence your climate progress but you lack the data and supporting activity
  • managers struggle to implement ESG policies
  • supply chain disruptions in critical minerals make it difficult to purchase electronics
  • lack of transparency by your waste supplier
  • mishandled eWaste by your waste supplier
  • mishandled eWaste by your employees
  • lack of choice in choosing waste suppliers
  • reputational damage from fines by regulators

Supply Chain Diversity

Are the companies you rely on for your electronics based in countries that are vulnerable to supply chain disruption? During COVID, companies began to realize how narrow their supply chains were. They thought they had alternative suppliers, but after some research, concluded that all investigations led back to one or two companies, in one or two countries. Their supply chained lacked geographical and supplier diversity.

Your supply chain includes vendors that are hidden or so far down the supply chain that you do not track them. Shadow vendors are most likely to be capable of abuse.

OECD Due Diligence Guidance

The OECD recommendations for eownstream Market Makers, Manufacturers, and End users include:

1. Identify ‘choke points’ in supply chain (e.g. metal smelter or refiners)
2. Collect information on their upstream due diligence (e.g. both through individual efforts and industry auditing)
3. Use collective industry leverage to encourage improvement of upstream due diligence
4. Report publicly on due diligence efforts

Steps taken include the following:

  • Adopt a policy for responsible supply chains of minerals.
  • Assemble an internal team to oversee supply chain due diligence.
  • Ensure that the necessary budget resources are assigned and that a senior manager is ultimately accountable.
  • Communicate company policy, actions and expectations related to responsible sourcing to suppliers.
  • Companies should incorporate these expectations into supplier contracts and consider other ways to support the capabilities of suppliers to fulfil responsible sourcing expectations.
  • Establish an internal system of transparency, information collection, and records of supply chain due diligence processes, findings and resulting decisions.
  • Maintain records on the identity of smelters & refiners, or any other suppliers at points of transformation where the mineral is processed to reach commercial market quality, once this information is collected.

United States Geological Survey (USGS)

The USGS Mineral Resources Program (MRP) collects data on non-fuel mineral resources. They list 35 mineral commodities as critical. The USGS are developing a national-scale, geospatial database that is the authoritative source of the most important mines, mineral deposits, and mineral districts of the United States.

Conflict Minerals

Conflict minerals, as defined by the US legislation, currently include the metals tantalum, tin, tungsten and gold. Conflict free minerals are those that were extracted and did not directly or indirectly benefit armed groups in the Democatic Republic of the Congo (DRC).


The largest tantalum deposit in the U.S. is the Round Top deposit in Texas, which contains reported resources of 480 million metric tons. There are no current U.S. producers of tantalum. Brazil's Advanced Metallurgical Group owns the world's second largest tantalum company, with the MIBRA project. 39 percent of US tantalum imports come from China.


Tin is used in solders for electrical/electronic circuits. Belgium’s Metallo Chimique, Peru-based, privately owned Minsur are the two largest tin companies not based in China. Metallo Chimique has a recycling and refining facility.


Bolivia's Comibol, a state-owned mining umbrella company, is one of the world's largest providers of tungsten. In Europe, Wolfram’s Mittersill mine, which is located in Salzburg, hosts the largest tungsten deposit in Europe. Spain's Almonty Industries and W Resources and Portugal's Panasqueira and Borralha mines are among the largest tungsten mines.


Less than 0.1% of potential sites will lead to a productive gold mine. Only 10% of global gold deposits contain sufficient gold to justify further development.

Minerals Processing

Minerals processing requires breakdown, concentration, and doping. Up to 90 percent of minerals processing occurs in China. The US processes around 4%. Each mineral processing facility costs up to 1 billion usd. The US has fewer than ten.  

Critical Minerals

Our supply chains for "clean" energy rely on critical minerals. Most critical minerals are processed in China. Nickel is sourced from China, Indonesia and Russia. The semiconductor industry relies on palladium from China and Russia and neon from Mariupol and Odessa in the Ukraine. Polysilicon for solar panels is currently sourced from China and Russia. Cobalt for mobile phones is supplied by China and Russia.

Recent wars reveal an overreliance on countries that are unable to provide critical minerals. The US acknowledges the importance of recycling, but does not support their position with funding. Also missing is a plan for increasing the number and quality of recycling plants needed to handle complex devices. At present, the Biden administration is focused on battery recycling - principally for the 1 trillion dollar automotive industry.

Your supply chain includes vendors that are hidden or so far down the supply chain that you do not track them. Shadow vendors are most likely to be capable of abuse.

Your supply chain includes vendors that are hidden or so far down the supply chain that you do not track them. Shadow vendors are most likely to be capable of abuse.

Defence Production Act (DPA)

The DPA is used to motivate change. The DPA will do at least two things. One, offer new permits to mine for critical minerals. They say there should be engagement with Native American tribes and local communities, but the details are scant.


As you look at your suppliers, you can leverage tech to bring the data into a data lake. Once in the data lake, use artificial intelligence and natural language processing to cut through the noise and understand what matters.

Data aggregators may have some information. You don't need to know the entity name all the time. You could use import/export data to see the region. It may be possible to find subcontractor information.

The Social part of ESG

Electronic waste is a sector that is notorious for poor labor practices, when viewed on a global scale across the supply chain. Ask your vendors across your supply chain questions about employee working conditions.


See how your entities in your eWaste supply chain do business. Buy from manufacturers and retailers who use recycled materials, and treat their employees with dignity.

Shareholders are suing corporations that previously held themselves out as sustainable or ESG compliant. The reputational loss and stock value loss is a new area of risk.


Support the creation of an eWaste mining program. Report your Scope 3 emissions across all 15 categories for all waste streams. Track the amount of methane created by the eWaste you send to landfill.

Work with us before tipping points become a permanent reality.

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