In order to assess the progress of inquiries on 3TG, is it appropriate to request exactly when suppliers will disclose all of their SOR data?
The CFSI recognizes that supply chain due diligence is a continual, ongoing process to be undertaken by companies. At this stage, it may not be possible to obtain the full cooperation of all suppliers; however, companies should employ reasonable and good faith efforts in their supply chain due diligence and expect their suppliers to improve their due diligence performance over time. In some cases, suppliers may be reluctant to make a commitment on the timing of the process to identify SORs. In order for suppliers to smoothly implement supply chain inquiries, it is recommended that impractical requirements are avoided. To facilitate information collection, the CFSP and the CMRT provide a common platform and standards for all industries. Furthermore, the OECD and SEC both contemplate that information will improve over time. Therefore, companies should feel comfortable sharing relevant information received to date while realizing that data will improve subsequently. Companies should conduct annual inquiries, but the timing of the inquiries are at the discretion of each company.