Gaps and missing supplier data

A gap in supplier data is a named piece of missing evidence, with a reason for the absence, an owner for follow up, and a next step with a date. Missing data is normal in a long supply chain, and the failure is not the gap itself but a record that hides the gap or fills it by assumption. The gap log should state the material, the tier, the supplier, the evidence requested, the date requested, the response received, and the reason the evidence is not available. Each gap should be graded by whether it blocks a risk assessment, a passport entry, or a public claim. A gap that blocks a claim must stop the claim until the evidence arrives or the claim is narrowed.

A data gap means evidence that was requested or needed and is not held in the file at the date of the record. The scope covers gaps for covered raw materials, for the battery model and period stated, including gaps caused by supplier refusal, upstream opacity, or a change of supplier.

What is the legal frame for this record?

Gaps and missing supplier data sits inside that sequence, so a record that shows only one step leaves the chain of reasoning incomplete. A data manager maintaining a gap log across three suppliers therefore needs a file that shows the policy, the owner of the policy, the date of adoption, and the review cycle. A missing refiner identity for one quarter of nickel supply should be logged as a quantity gap, with the affected quantity stated, so the passport and report claims can be limited to the quantity that is evidenced.

How is the chain mapped?

The map should name each tier that handles gaps and missing supplier data, record the function of each actor, and note where material changes form, such as refining, precursor production, cathode production, cell production, and pack assembly. The gap log, request records, and escalation notes should be tied to a named tier, a named site where that information is known, and a date. A data manager maintaining a gap log across three suppliers should record gaps on the map itself, with the reason for each gap and the next step planned. A gap should never be closed by copying a value from another period, another supplier, or another material, and the log should record the method used to close each gap when evidence finally arrives.

How is evidence judged?

A supplier statement, a contract clause, a third party audit summary, a mass balance record, and a chain of custody document do not carry equal weight, and the record should say which type supports each claim about gaps and missing supplier data. The gap log, request records, and escalation notes needs a source name, a collection date, a coverage period, and a statement of what was actually checked. A data manager maintaining a gap log across three suppliers should separate facts received from conclusions drawn, so a later reviewer can test the conclusion. A missing refiner identity for one quarter of nickel supply should be logged as a quantity gap, with the affected quantity stated, so the passport and report claims can be limited to the quantity that is evidenced.

How is risk identified and assessed?

A red flag can be a place of origin, a processing route, a supplier practice, a change of ownership, or a gap in records for gaps and missing supplier data. A gap should never be closed by copying a value from another period, another supplier, or another material, and the log should record the method used to close each gap when evidence finally arrives. A data manager maintaining a gap log across three suppliers should date each assessment and name the person or function responsible for the next review.

How is mitigation planned and followed up?

For gaps and missing supplier data, the plan should state the risk addressed, the action chosen, the supplier or site involved, the support offered, and the evidence that will show whether the action worked. The gap log, request records, and escalation notes collected after the action should be compared with the position before the action, using the same measure where possible. A missing refiner identity for one quarter of nickel supply should be logged as a quantity gap, with the affected quantity stated, so the passport and report claims can be limited to the quantity that is evidenced.

How is reporting checked?

The due diligence report should summarise the policy, the management system, the risks found, the actions taken, and the verification arranged for gaps and missing supplier data, without disclosing confidential commercial detail that the Regulation does not require to be published. A data manager maintaining a gap log across three suppliers should check that every public claim can be traced to an internal record, and that the report date, coverage period, and scope match the internal file. A gap should never be closed by copying a value from another period, another supplier, or another material, and the log should record the method used to close each gap when evidence finally arrives.

How is a blocking gap handled before a public claim?

A blocking gap, such as a missing refiner identity for a material quantity that would be named in a public report, stops the claim for that quantity. The handler narrows the claim to the evidenced quantity, states the gap quantity in the internal file, and records the owner and deadline for closing the gap. A worked example: a report draft claims a full year of nickel sourcing, but one quarter lacks refiner data. The published claim is narrowed to three quarters, the gap quarter is logged, and the supplier is given a dated request with escalation. When the data arrives, the claim can be widened in the next report, with the new evidence filed. The gap is never closed by repeating the previous quarter figure.

An open gap log is a working record, and the file is judged by whether gaps are visible and owned, not by whether the log is empty.