Skip to main content


On 04/08/2022, Ethical Consumer viewed Apple Inc's SEC Form SD dated 9/02/2022. Ethical Consumer also viewed Apple Inc's Supplier Code of Conduct.

Conflict minerals are minerals mined in conditions of armed conflict and human rights abuses, notably in the eastern provinces of the Democratic Republic of Congo (DRC). The minerals in question are Tantalum, Tin, Tungsten and Gold (3TG for short) and are key components of electronic devices, from mobile phones to televisions.

Ethical Consumer expected all companies manufacturing electronics to have a policy on the sourcing of conflict minerals. Such a policy would articulate the company's commitment to conflict-free sourcing of 3TG minerals and a commitment to continue ensuring due diligence on the issue. The policy should also state that it intended to continue sourcing from the DRC region in order to avoid an embargo and that the company had membership of, or gave financial support to, organisations developing the conflict-free industry in the region.

The company's policy outlined its commitment to conflict-free sourcing:
"In particular, third party audits play a significant role in providing assurance that smelters and refiners have appropriate due diligence systems in place, while helping to ensure that operations and sourcing practices are aligned with the OECD Due Diligence Guidance, and do not support conflict, including in the DRC or adjoining countries".

The following statement demonstrated the company's commitment to continuing to source 3TG minerals from the DRC region:
"We continue to source 3TG and other minerals, such as cobalt, responsibly, while working to improve conditions in and around mining communities, including in the Democratic Republic of the Congo (“DRC”) and adjoining countries."

This commitment was considered to be an important part of a good conflict minerals policy because to simply avoid sourcing minerals from the DRC region altogether could harm the local economy and cause further problems in the region.

The company demonstrated a commitment to ongoing due diligence. It stated:
"Conducting human rights due diligence in alignment with the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) and related Supplements (the “OECD Due Diligence Guidance”) and the United Nations Guiding Principles on Business and Human Rights (“UN Guiding Principles”) is the foundation of Apple’s responsible sourcing program for primary sourced minerals."

The company found to be a member of the Responsible Business Alliance, the RBA’s Responsible
Minerals Initiative, the Public Private Alliance for Responsible Minerals Trade, the European Partnership for Responsible Minerals and the Responsible Artisanal Gold Solutions Forum.

The conflict minerals policy was included in the Apple Supplier Code of Conduct, which suppliers were required to adopt.
"The Apple Supplier Code of Conduct... requires suppliers, smelters, refiners, and recyclers in our supply chain to identify and assess a broad range of risks beyond conflict, including social, environmental, and human rights risks. Suppliers are also required to review reported incidents and public allegations linked to their smelters and refiners, and to participate in 3TG traceability and third party audit programs to address and mitigate identified risks."

The company outlined the steps it would take to identify, assess, mitigate and respond to risks within its supply chain:

"OECD Step 1: Strong Company Management Systems
OECD Step 2: Identification and Assessment of Risk in the Supply Chain
OECD Step 3: Strategy to Respond to Identified Risks
OECD Step 4: Independent Third Party Audit of Supply Chain Due Diligence
OECD Step 5: Report on Supply Chain Due Diligence"

The report offered comprehensive detail surrounding how each step would be approached and enforced.

The company demonstrated a commitment to only using 3TG minerals from smelters that have been audited and verified as conflict free by the Responsible Mineral Assurance Process. It stated that "since 2015, (Apple) have continued to reach a 100 percent rate of participation in third party audit programs by identified smelters and refiners in our supply chain... If a supplier is unwilling or unable to meet Apple’s requirements, we will
terminate applicable business relationships".

The company published a list of smelters or refiners (SOR), however this was considered to be inadequate as it did not include RMAP status information.

Overall, Apple Inc received a best Ethical Consumer rating for conflict minerals policy and practice and lost no marks under the Human Rights and Habitats & Resources categories.


SEC Form SD 9/02/2022 (4 August 2022)