Conflict Minerals Form SD AI Agent

What this agent does

Chases the response, never the conclusion

A supplier answers for its own tier and goes quiet on the one below, and the chase carries on down.

A template returns, and it is reconciled against the bill of materials it was meant to cover, part by part.

Reason

A smelter is named, and it is checked against the conformant-smelter list, not against the supplier naming it.

A filing date approaches, and it is re-derived from the calendar year, not from the fiscal year.

A deadline falls on a Sunday, and Exchange Act Rule 0-3(a) moved it to Monday 1 June in 2026.

Decide

A product is described as DRC conflict free, and that one sentence is what puts an audit back in scope.

An Annex I volume threshold is crossed, and Regulation (EU) 2017/821 reaches worldwide, not the DRC.

Out

A record is kept whole — the responses, their dates, the non-responders and the officer who signed.

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

AgentHuman

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.

5DecisionBranches at the completeness gate

Coverage sufficient

Goes to the supply chain counsel to release.

Anything thin

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 required8 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 boundaryAgent 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 partIllustrative example

Part

Chased as

Tier reached

Response of record

Confidence

Held for

Tantalum capacitor, power rail

CMRT reissued, smelter names incomplete

Third tier of four

Supplier return, 14 April 2026

Held unfiled

The supply chain counsel, in person

As receivedTaken 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 hereItem 1.01(a) asks for a reasonable inquiry, and the officer runs it.

ActionRelease the recordAppend evidenceSend to counsel

What the score decidesBelow the configured threshold the record picks up a counsel read before.

Value

Where AI adds value

The same four claims, placed at the point in the workflow where each one applies.

Where the value landsValue 01 – 04

Every partFrom the bill of materials

03Evidence

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.

01Approved path

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.

02Human review

Where the certification lands

Our mining agent closes on the certification sitting downstream. Downstream is the manufacturer who files, and that is this page.

04Build 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 templatesCMRT · EMRT returns
Conformant-smelter list

Supplier recordsSupplier master · contacts
Response and chase history

Product and part recordsPLM · bill of materials
Part master · AVL

Agent

Conflict minerals inquiry

Reads the template
Chases the tier
Holds for the officer

Filing and disclosureForm SD workpapers
Website disclosure posting

Observability & evaluationOpenTelemetry · 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 defenceInward → L1 · closest to the model

L6Rollback / safe modePull the agent back to chasing responses only when evaluation or production signals degrade.Roll back

L5Version monitoringTrack model, prompt, chase-rule and list changes; 17 CFR 240.13p-1 was unamended on 23 August 2026.Track

L4TraceabilityRecord each response, the tier it came from, the reasoning applied and each read.Record

L3Officer releaseHold the record for a named human; it governs the filing, and not whether an origin is known.Gate

L2Policy guardrailsTest the record against Item 1.01(a) and (b), both still required, and the tiers reached.Restrict

L1Confidence thresholdsRoute a thin record to a counsel read before the supply chain counsel sees it.Require review

Model coreRecord built — the responses, the smelters, the tiers reached and completeness

L1 – L2Test whether a record may stand

L3Puts the filing in a person's hands

L4 – L5Keep the part and the smelter behind it

L6Holds 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

Depth of coverage ▼

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 lifecycleDirection of processing →

01 · Retrieval1 mode

IK-03

Superseded list read

The conformant list read is not the one current that day.

Stage gathersThe templates, the tiers, the smelters and the dates

02 · Reasoning2 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 proposesThe responses, the tiers reached and completeness

03 · Tool / write2 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 writesOnly where write access and approval policy allow it

04 · Output1 mode

IK-01

Filed, inquiry unrecorded

The record shows a filing but not what produced it.

Stage returnsThe record an officer signs and a reviewer reads

05 · Change / Version1 mode

IK-07

Calendar carried forward

A filing date is reused rather than re-derived each year.

Stage tracksModel, 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

See the complete Electronics failure-mode catalogue →

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 aggregateIllustrative example

Slice	Failure rate	Lift	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 stagesSwitchback — the path turns at Improve and returns at Learn

01Detect

Counsel-correction rate rises in one product group.

02Diagnose

The declaration that answered for one tier and went silent on the one below is read back until one cause remains.

03Improve

Every change leaves numbered, with the parts that caused it filed beneath.

04Verify

A single red part case is enough to keep the release back.

05Learn

The case is permanent, and the inquiry rules are rewritten with it.

Learn → DetectThe 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.

02Supplier, PLM and template sources.

03Smelter-list, tier-depth and chase-rule mapping.

04Template ingestion and normalisation.

05Bill-of-materials and smelter binding.

06Completeness scoring and counsel routing.

07Officer release workflow.

08Supplier and PLM integration.

09Smelter and response cases.

10Guardrails and inquiry controls.

11Inquiry-trail instrumentation.

12Deployment, documentation and Agent Care handover.

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 priceConfirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.

Separate from buildBuild 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 bringWe build with it

01Your bill of materials and supplier master → Part ingestion and supplier mappingWeek 1

02Representative returned templates → Record baseline, tier binding and response captureWeek 2

03Your chase rules and filing calendar → Smelter-list, tier-depth and chase-rule mapping and the automation boundaryWeek 1

04Access to relevant APIs, feeds or exports → Supplier, PLM and template assessment, then integration setupWeek 2

05Inquiries you would not want re-run → Response cases and the evaluation suiteWeek 4

06What no country-of-origin inquiry may conclude → Completeness scoring, counsel routing, guardrails and release controlsWeek 3

07A named executive officer to sign → Officer release workflow, then pilot and production validationWeeks 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 W1W2W3W4W5W6

Discovery W1

Build W2 – W3

Evaluate W4 – W5

Pilot & Launch W5 – 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 bandA bar covers only the weeks its own work is named in. The doubled fifth week is real work, not padding.

At the end of W6When the inquiry record validates, Agent Care takes the agent on.

DurationSix-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.

Discuss this agent →

Nestack Agents · Conflict minerals inquiryAGT-EL-19 · Agent Care available after launch