Many of the advanced technologies in our portfolio may use minerals and materials that are potentially mined in conflict-affected and high-risk areas.
Supporting Supplier Communities
GM is committed to supporting communities in which we source minerals. For example, we recently became members of the Pact Youth Apprenticeship Program in the Democratic Republic of the Congo. Pact implements various programs in the Lualaba province with the aim of reducing child labor in mining. These activities include community sensitization, positive parenting training, coordination of community stakeholders and strengthening of civil society organizations.
Since 2017, Pact has assisted youth in the Kolwezi area to thrive in alternative livelihoods to mining by equipping them with vocational and business skills. Pact analyzes the feasibility and profitability of trades within a specific community through a market study. Then, Pact identifies mentors from the selected trades and chooses them based on their good character, solid professional experience, proof of legal establishment and a workshop in the target community. Finally, adolescent miners, from 15 to 17 years old, are selected to undergo a six-month intensive apprenticeship in a trade.
To identify and mitigate human rights risk in the sourcing of these raw materials, our due diligence practices undertaken in connection with our Responsible Materials Program and our Conflict Mineral Program are aligned with the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
We enjoy strong management support for conflict mineral supply chain due diligence. A compliance committee comprised of cross-functional GM leaders and an executive steering committee provide leadership and direction for the program.
Third-party cobalt and mica mining activities in certain regions of the world have been associated with potential human rights violations. To help mitigate this risk, we annually request all Tier I direct vehicle component suppliers with cobalt product content to complete the Cobalt Reporting Template, the Mica Reporting Template (MRT) and the Conflict Minerals Reporting Template (CMRT) to help GM map the supply chain for components containing these minerals.
Similarly, we annually utilize the CMRT to survey 100% of Tier I suppliers with products containing tin, tungsten, tantalum and gold (3TG) to gain visibility of the smelters or refiners (SORs) of these minerals in our supply chain. In 2021, 2,602 supplier locations were considered in-scope for GM’s Conflict Minerals Program, and we received responses from 94% of these suppliers.
After SORs are identified, they are validated to determine whether they have passed the Responsible Minerals Assurance Process (RMAP). This process, administered through the Responsible Minerals Initiative (RMI), employs a risk-based approach to validate SORs’ processes in place for responsible mineral procurement. Those SORs that have passed this assessment are considered conformant to the RMAP.
We work with our suppliers regularly to provide education and awareness, including training, webinars and supplier bulletins. We are active in the AIAG Responsible Materials Work Group, which works on common automotive industry solutions with other original equipment manufacturers (OEMs) and suppliers regarding conflict minerals and high-risk materials. In 2021, we joined the Initiative for Responsible Mining Assurance, a third-party certification of industrial mine sites for mined materials, and RCS Global Better Mining Initiative for small and artisanal mines.
It is our aim to work with suppliers through the tiers of our supply chain to identify nonconformance to our policies and code of conduct and remedy nonconformance. If we cannot find an avenue to mitigate the risk, we reevaluate the business relationship.
We are an active participant within the RMI and corresponding RMI working subgroups. The Smelter Engagement Team is one of these subgroups that enables us to have direct SOR engagement. We have found that coordinated outreach to nonconformant SORs can be effective at encouraging RMAP participation. Likewise, GM has participated in RMI-sponsored SOR RMAP pre-audit visits, with the most recent visit being in 2019 with an Indian gold refiner.
If SORs have not been validated as conformant to the RMAP, we encourage them to participate in this third-party assessment. GM sent communications to 10 3TG SORs during the 2021 calendar year. Due to COVID-19 concerns and restrictions, GM did not conduct on-site SOR visits in 2020 or 2021.
The extraction of cobalt, a component of lithium-ion batteries, raises industrywide concerns around the use of child labor. Through efforts and membership in RMI, we are working to mitigate human rights risk in the cobalt supply chain by:
- Identifying and assisting with the disposition of cobalt refiners to determine if these companies meet RMI’s industry specification for an eligible cobalt refiner.
- Performing outreach to cobalt refiners that are not conforming to the RMI industry standards to encourage them to go through the RMAP for cobalt.
- Functioning as a single point of contact on behalf of RMI for several cobalt refiners, assisting them in their pursuit to join the RMAP.
We are working collaboratively within RMI’s mica subgroup to proactively develop processes to reduce human rights risk in the mica supply chain. The RMI subgroup is working with the Responsible Mica Initiative in the following areas:
- Identifying processors of mica in the supply chain using a company identification questionnaire.
- Creating a joint due diligence standard for these processors.
- Dispositioning processors of mica using RMI methods and adding them to the RMI smelter/refiner database.
These efforts will allow us to expand our due diligence scope to mica. In 2021, we requested MRTs from all suppliers with mica content in their products. Doing so will allow GM to gain visibility of mica processors in our supply chain to identify risk and conduct due diligence to reduce human rights and environmental harm in the mica supply chain.