Have I Done Enough Conflict Minerals Due Diligence?
As the conflict minerals reporting deadline approaches, many companies are asking what is considered sufficient due diligence to meet Dodd-Frank 1502.
Although only publicly traded companies are required to file with the SEC by June 1, privately held companies may have customers that do have to file conflict minerals Form SD or CMRs with the SEC. This means publicly traded companies will need information about the use of tin, tungsten, tantalum and gold (3TG) in the products produced by their privately held company suppliers. Hence, both publicly and privately held companies could be impacted by Dodd-Frank 1502.
The SEC rule Dodd-Frank 1502 and associated guidance is not particularly prescriptive in nature. Rather it just simply specifies one must use a nationally or internationally recognized framework for due diligence. This offers a bit of flexibility in terms of selection and implementation of due diligence actions. You can pick and choose based on what is most appropriate given the characteristics of your supply chain and what is most likely to succeed given your company’s business culture.
For more guidance on conflict minerals reporting, check out a recent webinar with Source Intelligence, a company that assists global brands engage with their supply chains for social responsibility data.
Remember, even if you don’t have to comply with the SEC, your customer(s) may and require you to get up close and personal with you supply chain. Engaging with your supply chain can be time consuming and tedious, at best, so develop a plan that will be followed within your organization from the get go. There are some great Q+As in the webinar mentioned above that could answer many questions you may have.