Q. We are trying to gather the names and locations of all the downstream vendors in the recycling chain that handles our Focus Materials, but are having trouble obtaining this information from one of our downstream vendors. Any suggestions for us?
A. If a company is absolutely unwilling to provide downstream names and locations, unfortunately you will need to find a new downstream vendor. Sometimes when companies realize that they will be losing your business, they will work with you to provide the information you need.
If your prospective downstream vendor is R2 certified, they are required under Provision 7 (Tracking Throughput) to provide the names and locations of all downstream vendors in the recycling chain to other R2 certified companies or candidates for the purpose of conducting due diligence. It is permissible for them to require non-disclosure agreements.
Occasionally conflicts arise when a company requests more information than what is required by the R2 Standard. Ensure that your conflict is regarding the specific information required by the Standard. If that is the case, and your downstream vendor will not provide the names and locations of downstream vendors that manage your focus materials, you can file a non-conformance complaint with their Certifying Body.
Excerpt from R2:2013 Provision 7(b):
An R2:2013 electronics recycler shall provide, to each customer that is R2 certified or in the process of R2:2013 certification, upon request and with appropriate intellectual property and commercial controls as legally appropriate and required by the discloser, the names and locations of all downstream vendors in the recycling chain that handle said customer's FMs.
Excerpt from the Guidance Document:
R2 recyclers may take appropriate steps to protect their confidential business information, such as requiring auditors, CB's and customers to sign Non-disclosure Agreements prior to reviewing Provision 7.