On 5th September 2021, Ethical Consumer viewed Google LLC's website for the company's conflict minerals policy. A link to the company’s Conflict Mineral Policy redirected to Google’s parent, Alphabet’s Conflict Minerals Policy.
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: "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." This statement also demonstrated the company's commitment to continuing to source 3TG minerals from the DRC region.
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 also demonstrated a commitment to ongoing due diligence.
The company was found to be a member of Responsible Mineral Initiative; Public-Private Alliance for Responsible Minerals Trade; Responsible Artisanal Gold Solutions Forum.
The conflict minerals policy was included in supplier contracts, and suppliers were required to adopt an equivalent policy. It 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."
The company outlined the steps it would take to identify, assess, mitigate and respond to risks within its supply chain in its 2019 Conflict Minerals Report. These were based on OECD guidelines.
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: "We expect our suppliers to source only from certified conflict-free smelters, such as those audited by the Responsible Mineral Initiative’s (RMI--formerly the Conflict-Free Sourcing Initiative) Responsible Minerals Assurance Process (RMAP), or another third party assessment program."
The company published a list of smelters or refiners (SOR); however, this was considered to be inadequate as it did not include the RMAP status of the smelters
Overall, Google LLC received a best Ethical Consumer rating for Conflict Minerals Policy and Practice and lost no marks under the Human Rights and Habitats & Resources categories in relation to this.