In September 2019, Ethical Consumer searched the Google website for information on the company’s
approach to conflict mineral sourcing. A link to the company’s Conflict Mineral Policy redirected to
Google’s owner, Alphabet’s Conflict Minerals Policy.
1. Conflict mineral policy
The policy stated: “We believe it is essential to establish validated, conflict-free sources of 3TG within the Covered Countries [under the Dodd Frank act] so that these minerals can be procured in a way that contributes to economic growth and development in the regions.” It also committed to ongoing due diligence.
2. Multi-stakeholder initiatives / In-region mining initiatives
According to their membership lists, Google was a member of the following multi-stakeholder initiatives or a partner for the following in-region mining initiatives:
- Responsible Mineral Initiative
- Public-Private Alliance for Responsible Minerals Trade
- Responsible Artisanal Gold Solutions Forum
3. Supplier expectations
The company stated: “Google advises its suppliers to take similar measures with their own sub- suppliers to ensure alignment and traceability throughout the supply chain and back to the smelter. Furthermore, 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 to Google. Suppliers’ due diligence measures should be available to us upon request.”
However, it required due diligence but only recommended that its suppliers developed an equivalent conflict mineral policy.
4. Due diligence processes
Alphabet’s 2018 Conflict Mineral Report recorded the company’s actions in the year against each of the five stages OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, providing multiple bullet points for each.
5. RMAP smelters
Google’s 2018 Responsible Supply Chain Report stated that it would: “Continue to work toward ensuring that our suppliers source only from smelters that are conformant with the Conflict-Free Smelter Program assessment protocols.” “We have made good progress in sourcing from Compliant tin (100%), tungsten (100%), tantalum (100%), and gold (98%) smelters and refiners.”
6. Smelter or refiners list
The report also included a list of smelters, which specified country of location and material supplied. However, it did not indicate which were RMAP conformant, and as the report stated elsewhere “We communicated with suppliers that reported smelters who were not yet identified as RMAP conformant”, this was considered necessary.
Overall Google was considered to have Ethical Consumer's best rating for its concflict minerals policy.