Blog

Notes from the sub-tier

  1. Field notes: the candidate list that named a refinery three suppliers swore didn't exist

    A compliance manager's field notes on the gap between a tier-1 supplier's declared map and what's really running on the ground in a producing region.

  2. When the smelter field on a CMRT is blank: what it means

    A blank smelter field on a CMRT can mean several different things. Here's how to tell them apart before you chase a resubmission.

  3. The OECD five-step framework and where satellite screening actually fits

    A plain walkthrough of the OECD five-step due diligence framework and the specific step where satellite screening helps when no supplier list exists.

  4. Briefing an Auditor With a Candidate Site List Before a Tier-2 Visit

    A practical guide to building an auditor's briefing packet around a candidate site list before a tier-2 facility visit or CAP follow-up.

  5. How to tell a brick kiln from a lime kiln in satellite imagery

    A field guide to reading kiln stack shape, zigzag vs bull's trench layout, and firing-site signatures when mapping undeclared tier-2/3 sites.

  6. What counts as a declared supplier under UFLPA and forced labor import bans

    What "declared supplier" means under UFLPA, how it differs from the entity list and WRO list, and why tier-1 disclosure rarely covers tier-2/3 sites.

  7. How to tell a tannery from a textile mill in satellite imagery

    How to tell a tannery from a textile mill in satellite imagery, from effluent pond color to roofline and yard layout.

  8. What counts as a conflict-affected and high-risk area under OECD guidance

    A plain-language look at how OECD due diligence guidance defines CAHRAs, and why the definition alone doesn't tell you which sites sit inside one.

  9. What a smelter's physical signature looks like in satellite imagery

    What distinguishes a smelter's footprint in satellite imagery: stack geometry, slag piles, material handling, and thermal signature.

  10. What is the RMI conformant smelter and refiner list?

    What the RMI conformant smelter and refiner list covers, how a facility gets on it, and why it only shows the sites someone named.

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