What is audit gap closure?
If the auditor and ARC determine the SOR has not fully demonstrated compliance to the CFSP protocol, the auditor and ARC will identify items where compliance was not properly demonstrated (gaps) and the non-compliance letter that will include a brief explanation of additional information needed to determine compliance. All findings of non-compliance during the audit will be noted in the non-compliance letter issued to the SOR. If the ARC determines the SOR is not compliant to the CFSP protocol:
- The SOR must provide the necessary supplemental information (in accordance with the non-compliance letter) to the auditor within 60 calendar days of issuance of the non-compliance letter as a means to address the identified gap(s).
- The remaining 30 calendar days of the 90-day gap closure timeline is allocated for the auditor to review and validate the provided supplemental information and subsequent review by the ARC. If necessary, an auditor may be required to complete an additional onsite visit (at the smelter’s/refiner’s expense) to review the supplemental information and resolve the identified gaps.
- If the gaps are resolved and the SOR subsequently meets the requirements of the CFSP protocol per the recommendation of the auditor and determination by the ARC, a Compliance Letter is issued to the SOR.
- If the SOR that has a repeat non-compliance issue identified, or was unable to complete closure on open items within the 90-day post-audit mitigation period, the SOR will be deemed as non-compliant and will be exempted from participating in the CFSP for a period of six months. A SOR may request an audit at the conclusion of the six-month exemption period.
- If at the end of the 90-day post-audit time period the ARC concludes the SOR remains non-compliant to the CFSP protocol but the SOR does not agree with that conclusion, the SOR may challenge the non-compliance conclusion by filing a written appeal to the CFSI. The CFSI’s Appeals and Complaints Procedure can be found here: http://www.conflictfreesourcing.org/conflict-free-smelter-program/cfsp-audit-firm-and-auditor-approval/