In August 2018 Ethical Consumer viewed Google's website for the company's conflict minerals policy.
Google's SEC filing form SD for the year ended 2017 was viewed as well as its pubicly available policy on its website (https://abc.xyz/investor/conflictminerals/).
1. Company's commitment - the company articulated its commitment through its publicly available policy on its website. "We believe it is essential to establish validated, conflict-free sources of 3TG within the Covered Countries so that these minerals can be procured in a way that contributes to economic growth and development in the regions. We believe a widespread withdrawal from trade with the Covered Countries by US companies should be avoided."
2. Conflict-free initiatives - Google had been a member of the Conflict-Free Sourcing Initiative since 2013; it had supported the Solutions for Hope Gold initiative in 2014 and in 2015, Google joined the Public-Private Alliance for Responsible Minerals Trade.
3. Supplier contracts - Under the Google Supplier Code of Conduct, Google expects its suppliers to perform due diligence on the source and chain of custody of minerals used in the manufacturing of products they supply.
4. Process - Google stated that its due diligence measures were designed in accordance with the framework set forth in 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, Third Edition, 2016 (“OECD Guidance”), and the related Supplements for 3TG.
5. Commitment to sourcing from audited smelters - Google stated "We expect our suppliers to source 3TG from conformant conflict-free smelters such as those audited through the RMI's RMAP(http://www.responsiblemineralsinitiative.org), perform due diligence on the source and chain of custody of the 3TG used in our products, and provide their due diligence measures to us upon request."
6. List of smelters - Google listed its smelters at the end of its SEC Form SD.
Overall Google Inc received a best Ethical Consumer rating for conflict minerals policy.