The use of ‘conflict minerals’ in electronics and batteries has been a controversial subject for years. The incredible growth of consumer electronics has sprung demand for several rare minerals and it fueled conflicts, especially in Congo, where work conditions are known to be awful.

A report by Amnesty International and Afrewatch published last year pointed directly to battery makers and their clients as fueling the conflicts. It named several automakers like Mercedes, VW and BYD, as well as several battery manufacturers known to supply automakers, like LG Chem (GM and Nissan) – but Tesla and its battery supplier, Panasonic, were spared.

Nonetheless, the electric automaker released an update this week on its strategy to avoid conflict minerals and it shows how it can be complex to avoid them.

The report focuses on columbite-tantalite (tantalum), cassiterite (tin), gold, wolframite (tungsten), also known as ‘3TG’.

But the company says that it also has a “particular interest” for battery materials:

“Of particular interest has been the sourcing of raw materials contained in the battery cells used in Tesla’s products since battery cells are a major component of our business. Tesla has built strong partnerships with our direct battery cell suppliers. We work closely together to identify and engage with raw materials suppliers that support cell production, which does not typically include 3TG. We request and receive certificates of origin for raw materials, documentation and descriptions of risk management and mitigation policies at these suppliers, and as necessary visit production sites to observe, review, and discuss these risks and how they are addressed. We also check third party audits and evaluations to ensure our direct battery suppliers are complying with all relevant laws and their own corporate policies against child labor, human rights abuses, and other issues that affect responsible sourcing.”

As for 3TG, Tesla said that its growth in 2016 more than doubled the number of suppliers with parts that could use 3TG.

It significantly complicated Tesla’s supply chain:

“We identified 182 suppliers who supply 3TG in their products and required all of these suppliers to perform and report on their supply chain due diligence through the use of the CMRT. More than half of these identified suppliers in scope were new to our supply chain in 2016. We received 77 supplier responses with 3,525 unique smelters and refiners reported comprehensively. Due to our rapid growth and ramp in vehicle production, the number of smelters also more than doubled from the previous year. Tesla’s increase in product volume made it necessary to work with many new and different suppliers starting in calendar year 2016.”

The overall update highlights how complex it is for Tesla to track the source of the minerals used in its products, but nonetheless, they attempt to list all the known sources from Australia to Zimbabwe.

Here it is in full:

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