The U.S. Securities and Exchange Commission (SEC) continues to receive comment letters from a variety of organizations and individuals about whether to refine conflict minerals reporting requirements under Section 1502 of the Dodd-Frank Act.
Last year, the U.S. Sentencing Commission released a set of guidelines for fines assessed to organizations found responsible for federal offenses. The guidelines specify that companies with an “effective compliance and ethics program in place,” including those supported by a third party service provider, can qualify to have their fines reduced by up to 95%.
Approximately 1,200 publicly traded companies filed Conflict Minerals Reports with the SEC this year, in accordance with Dodd-Frank Section 1502 (Conflict Minerals Rule).
Source Intelligence has analyzed data collected from the 2015 filings, and mined meaningful insights for companies to utilize for the 2016 reporting year. Key findings demonstrate differences and similarities between industries, trends from past reporting years, and new findings from 2015.
On Wednesday, June 15th, The European Union (EU) agreed to outline a deal to facilitate a focus on transparency in the supply chain. This legislation concerns the sourcing of conflict minerals, not just in the Democratic Republic of the Congo, but from high-risk regions, worldwide.
"We need to step up to our responsibilities and finally break the vicious cycle of the trade in minerals and the financing of conflict," - EU Trade Commissioner Cecilia Malmstrom
Transparency is the key to complete traceability in supply chain. When transparency increases, companies have better insights into where their products are coming from and how they’ve been made. Data is the key in supplier networks that provides greater data accuracy, clarity, and insights, leading to more contextual intelligence shared across supply chains.
Year three of conflict minerals compliance is expected to be a year of both progress and change. Companies must continue to perform necessary due diligence to determine the source of tin, tungsten, tantalum and gold (3TG) in their supply chain and report on their process. However, what companies are required to declare may change.