Electronics AI agent · Conflict minerals
Conflict Minerals Form SD AI Agent
Chase the declaration down the tiers it has to cross — the smelter behind each part, who answered and who went quiet — and leave the Form SD to the officer who signs it.
- Typical delivery
- 4–6 weeks
- Deployment
- Your stack
- Officer signs
- Smelter level
- After launch
- Agent Care
What this agent does
Chases the response, never the conclusion
In
- 01
A supplier answers for its own tier and goes quiet on the one below, and the chase carries on down.
- 02
A template returns, and it is reconciled against the bill of materials it was meant to cover, part by part.
Reason
- 03
A smelter is named, and it is checked against the conformant-smelter list, not against the supplier naming it.
- 04
A filing date approaches, and it is re-derived from the calendar year, not from the fiscal year.
- 05
A deadline falls on a Sunday, and Exchange Act Rule 0-3(a) moved it to Monday 1 June in 2026.
Decide
- 06
A product is described as DRC conflict free, and that one sentence is what puts an audit back in scope.
- 07
An Annex I volume threshold is crossed, and Regulation (EU) 2017/821 reaches worldwide, not the DRC.
Out
- 08
A record is kept whole — the responses, their dates, the non-responders and the officer who signed.
- 09
Execute write actions only inside the approval boundaries agreed during implementation.
Product statement
The agent chases the responses and keeps the inquiry record; a named executive officer signs the Form SD on behalf of the registrant, and the issuer answers for it.
Example workflow
One part, template to signature
- 1Declaration requestedA CMRT or EMRT issued to the direct supplier of record
- 2Smelter list assembledSmelter and refiner names, the tier reached, response dates and the parts each answer covers
- 3Inquiry record builtCountry-of-origin reasoning per part, against the limbs Item 1.01 sets out
- 4Controls appliedCoverage checks, response-date checks, conformant-list checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and nothing is determined at any of them — the agent is chasing, and the counsel lane opens at the completeness gate.
Goes to the supply chain counsel to release.
Adds a securities counsel read first.
Supply chain counsel review
The record is held with its responses, its coverage and its gaps.
Release the record · Append evidence · Send to counsel
Released — signed by a named officer
- 6Supplier and part records updatedOnly where write access and disclosure policy allow it
- 7Outcome evaluatedCoverage margin, response completeness, counsel corrections and what a later review found
Corrections
Each counsel correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required
8 items
- Determining where a mineral originated.
- Concluding the country-of-origin inquiry.
- Signing or filing the Form SD.
- Calling any product DRC conflict free.
Automation boundary
Agent acts unaided
- ✓Chase the template down each tier and log who answered.
- ✓Reconcile each response against the bill of materials it covers.
- ✓Check each named smelter against the conformant-smelter list.
- ✓Hold the reasoning per part with the person who made it.
Nothing is filed except by a named executive officer, inside the agreed boundaries.
- Judging a supplier response adequate.
- Deciding an audit is or is not required.
- Writing or approving the website disclosure.
- Changes to templates, tiers or chase rules.
Example output
One part, annotated
Form SD is filed and not furnished, so Section 18 liability attaches and the record is read back years later.
Inquiry record · single part
Illustrative example- Part
- Tantalum capacitor, power rail
- Chased as
- CMRT reissued, smelter names incomplete
- Tier reached
- Third tier of four
- Response of record
- Supplier return, 14 April 2026
- Confidence
- Held unfiled
- Held for
- The supply chain counsel, in person
As received
Taken from the supplier return and the bill of materials — the chase reaches as far as a tier will answer.
What the record holds
- The returned template
- Smelter and refiner list
- Non-responder log
Why no inquiry call here
Item 1.01(a) asks for a reasonable inquiry, and the officer runs it.
What the score decides
Below the configured threshold the record picks up a counsel read before.
Action
Release the recordAppend evidenceSend to counselValue
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value lands
Value 01 – 04
Every part
From the bill of materials
Below the distribution path
Our procurement agent names the distribution path behind a candidate part; this one goes on down to the smelter under it.
Smelters, not suppliers
The control point under 17 CFR 240.13p-1 and under Regulation (EU) 2017/821 is the smelter or refiner, never the supplier that invoiced you.
Where the certification lands
Our mining agent closes on the certification sitting downstream. Downstream is the manufacturer who files, and that is this page.
Build an evidence trail
The part, the smelter list behind it and the officer who signed the filing stay on the record.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Declaration templates
- CMRT
- EMRT returns
- Conformant-smelter list
Supplier records
- Supplier master
- contacts
- Response and chase history
Product and part records
- PLM
- bill of materials
- Part master
- AVL
Agent
Conflict minerals inquiry
- Reads the template
- Chases the tier
- Holds for the officer
Filing and disclosure
- Form SD workpapers
- Website disclosure posting
Observability & evaluation
- OpenTelemetry
- Langfuse
- Supported monitoring/evaluation sources
Integration availability depends on the client's existing systems and API access.
Agent controls
Six passes between the model and the record
Six passes, each narrower than the one before. What is still there at the end is mapped below.
L6 · Outermost — last line of defence
Inward → L1 · closest to the model
- L1 – L2
- Test whether a record may stand
- L3
- Puts the filing in a person's hands
- L4 – L5
- Keep the part and the smelter behind it
- L6
- Holds the inquiry open when signals degrade
How Nestack evaluates it
Evaluate the whole assembly — not only the record that comes out.
Coverage runs the whole depth of the workflow, and every layer is cut by slice.
Surface — the record a reviewer reads
- E1Final-output evaluationDid the record hold the response the inquiry actually rested on?
- E2Step-level evaluationDid the agent use the right template, the right tier and the current smelter list?
- E3Tool evaluationDid it read and write the correct part and the correct supplier record?
- E4Confidence calibrationDo low-confidence records actually attract more counsel corrections?
- E5Slice evaluationHow does performance change across specific product groups?
- E6Business outcomeHow many records needed a correction before counsel released them?
Floor — the outcome the issuer answers for
Failure modes
Where each failure originates in the agent
Seven failure modes, each one set at the stage where it actually begins.
Agent lifecycle
Direction of processing →
01 · Retrieval
1 mode
- IK-03
Superseded list read
The conformant list read is not the one current that day.
Stage gathers
The templates, the tiers, the smelters and the dates
02 · Reasoning
2 modes
- IK-04
Relief read too widely
Staff relief on one paragraph is read across the rule.
- IK-06
Tier below dropped
The chase stops at the tier that answered.
Stage proposes
The responses, the tiers reached and completeness
03 · Tool / write
2 modes
- IK-02
Coverage assumed, not shown
Parts outside the return are counted as covered.
- IK-05
Reissue overwrites
A resent template keeps only the later answer.
Stage writes
Only where write access and approval policy allow it
04 · Output
1 mode
- IK-01
Filed, inquiry unrecorded
The record shows a filing but not what produced it.
Stage returns
The record an officer signs and a reviewer reads
05 · Change / Version
1 mode
- IK-07
Calendar carried forward
A filing date is reused rather than re-derived each year.
Stage tracks
Model, prompt, chase rules and the filing calendar
- Sev-1 · a filing leaves without an officer
- Sev-2 · a wrong smelter reaches the record
- Sev-3 · source degrades, record holds unfiled
Affected slices
One product group absorbs the corrections
A product-level smelter-coverage figure can read clean while one product group absorbs most of the corrections. Nestack reports the counsel-correction rate by product group, not only in total.
Slice performance — reported separately, not only in aggregate
Illustrative example| Slice | Failure rate | Lift | Lift vs. threshold | Status |
|---|---|---|---|---|
| Tungsten vibration-motor parts | 6.2% | 3.6× | Review | |
| Tantalum capacitor assemblies | 4.4% | 2.6× | Review | |
| Gold-plated connector parts | 2.9% | 1.7× | Watch | |
| Tin solder on board assemblies | 1.6% | 0.9× | Normal |
Bar: counsel-correction-rate lift vs. tin-solder board-assembly baseline · scale 0–4.0× · tick marks the 2.0× review threshold
2 of 4 slices over threshold
Evidence-linked improvement
What an unreconstructable record costs
A cycle ends when the unanswered tier-three supplier is a standing case. That suite is what the next inquiry run is measured against.
Improvement cycle · five stages
Switchback — the path turns at Improve and returns at Learn
- 01
Detect
Counsel-correction rate rises in one product group.
- 02
Diagnose
The declaration that answered for one tier and went silent on the one below is read back until one cause remains.
- 03
Improve
Every change leaves numbered, with the parts that caused it filed beneath.
- 04
Verify
A single red part case is enough to keep the release back.
- 05
Learn
The case is permanent, and the inquiry rules are rewritten with it.
Learn → Detect
The return edge. The next inquiry is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, record assembly, evaluation, integration, then production validation and handover.
Workstream
Week 1Week 2Week 3Week 4Week 5Week 6
- 01Inquiry-workflow discovery and boundary definition.Week 1
- 02Supplier, PLM and template sources.Week 1, Week 2
- 03Smelter-list, tier-depth and chase-rule mapping.Week 1, Week 2
- 04Template ingestion and normalisation.Week 2
- 05Bill-of-materials and smelter binding.Week 2, Week 3
- 06Completeness scoring and counsel routing.Week 3
- 07Officer release workflow.Week 3, Week 4
- 08Supplier and PLM integration.Week 5
- 09Smelter and response cases.Week 4, Week 5
- 10Guardrails and inquiry controls.Week 4
- 11Inquiry-trail instrumentation.Week 5, Week 6
- 12Deployment, documentation and Agent Care handover.Week 6
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallel
Final scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
| Capability✓ in scope · — not at this tier | PilotOne product group, one template | ProductionProduction inquiry workflow | AdvancedMultiple groups / regimes |
|---|---|---|---|
| Introduced at Pilot | |||
| Record assembly to your rules | ✓ | ✓ | ✓ |
| Named-officer release | ✓ | ✓ | ✓ |
| Smelter-list baseline | ✓ | ✓ | ✓ |
| Introduced at Production | |||
| Reporting by product | — | ✓ | ✓ |
| Release workflow in your systems | — | ✓ | ✓ |
| Approved write-back | — | ✓ | ✓ |
| Bill-of-materials integration | — | ✓ | ✓ |
| Introduced at Advanced | |||
| Multi-regime inquiry duties | — | — | ✓ |
| Cross-tier chase packs | — | — | ✓ |
| High part volume | — | — | ✓ |
| Multi-tier chase controls | — | — | ✓ |
| Build price | From $5,000 | From $8,000 | Custom quote |
- Final build price
- Confirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
- Separate from build
- Build pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bring
We build with it
01Your bill of materials and supplier master
→Part ingestion and supplier mapping
Week 102Representative returned templates
→Record baseline, tier binding and response capture
Week 203Your chase rules and filing calendar
→Smelter-list, tier-depth and chase-rule mapping and the automation boundary
Week 104Access to relevant APIs, feeds or exports
→Supplier, PLM and template assessment, then integration setup
Week 205Inquiries you would not want re-run
→Response cases and the evaluation suite
Week 406What no country-of-origin inquiry may conclude
→Completeness scoring, counsel routing, guardrails and release controls
Week 307A named executive officer to sign
→Officer release workflow, then pilot and production validation
Weeks 5–6
Nothing else is required
Deployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
The widths are the weeks the work actually takes, and the fifth week is shared for that reason.
Phase
W1
W2
W3
W4
W5
W6
- DiscoveryW1
- BuildW2 – W3
- EvaluateW4 – W5
- Pilot & LaunchW5 – W6
Week focus
W1Inquiry workflow discovery, chase mapping and the automation boundary
W2Source integration and the smelter-list baseline
W3Record assembly, chase logic and release controls
W4Evaluation suite, response cases and failure-mode testing
W5Supplier integration, pilot parts and targeted corrections
W6One filing year run under the supply chain counsel, then Agent Care handover
- Reading the band
- A bar covers only the weeks its own work is named in. The doubled fifth week is real work, not padding.
- At the end of W6
- When the inquiry record validates, Agent Care takes the agent on.
- Duration
- Six-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Electronics AI agent
Build a conflict minerals agent around the officer who has to sign.
Show us how a declaration reaches you today and who signs before 31 May 2027. Form SD is filed and not furnished, so it has to survive being read as a statement the issuer made, by a reviewer looking years later for what the inquiry rested on.
- Typical delivery
- 4–6 weeks
- Deployment
- Your bill of materials
- Officer signs
- Smelter level
- After launch
- Agent Care available
Nestack Agents · Conflict minerals inquiry
AGT-EL-19 · Agent Care available after launch