section 1502

Discussed Changes to Dodd-Frank Will Not Affect 2017 Conflict Minerals Filing Requirement

Article

The acting chairman of the U.S. Securities and Exchange Commission (SEC) announced this week that the agency would reconsider how to enforce the conflict minerals rule contained within the Dodd-Frank Act, Dodd-Frank Section 1502.

Higher Education Recognizes Conflict Minerals & the Issues Surrounding It. Source Intelligence Interviews Liz Cooper of Edinburgh University

Article

On March 1st, 2016, The University of Edinburgh adopted a policy aimed at cutting conflict minerals from their supply chain. Edinburgh has become the first university in the UK to develop a program aimed at mitigating the risk of conflict minerals in their supply chain.

Source Intelligence recently interviewed Liz Cooper, Research and Policy Manager, Department for Social Responsibility and Sustainability for the University of Edinburgh to gain some more insight into the development of their conflict minerals program:

Conflict Minerals Compliance Clock Ticks Away – Time’s Up

Corporations Should Have Comprehensive, Audit-Traceable Reporting Procedures in Place by Dec. 31; Supply Chain Risk Management Firm Source Intelligence® Urges Action Now for 2015 Reporting
Press Release

CARLSBAD, CA, July 25, 2014 /3BL Media/ – The two-year grace period for U.S. conflict minerals reporting requirements for large companies ends in less than six months, posing a significant challenge for the nearly 98 percent of companies that recently indicated they could not fully determine whether their products or components contained “3TG” conflict minerals, a leading supply chain management firm announced today.

Conflict Minerals Resource Center Launches New 2014 Training Module

Press Release

July 17, 2014 /3BL Media/ – Seven of the world's largest industry associations collaborated with Source Intelligence and Schulte Roth & Zabel LLP to launch a web-based training module within the Conflict Minerals Resource Center (CMRC). The goal of the joint initiative is to deploy an easy-to-use conflict minerals training tool for suppliers in the seven associations’ industries. The training module is based on the best practices developed by leaders in these industries and their suppliers during the 2013 conflict minerals reporting period.

Conflict Minerals Argument Over. Impossible? Over a Thousand Did It

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If the SEC posted a filing deadline and no one filed, Section 1502 of Dodd-Frank would have been a failure. Instead, public companies provided a resounding answer to the call for greater transparency. Now, NGO’s are reporting that over two-thirds of the mines that were run by militias four years ago are no longer under their control.

Conflict Minerals Due Diligence Leading the Way for Better Supply Chain Risk Management

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The unprecedented depth of the due diligence process required for conflict minerals compliance is uncovering surprises and risks that would have remained hidden without Section 1502 in place. Nearly 1,300 companies filed with the SEC as part of the conflict minerals compliance this past Monday. These companies now have a distinct competitive advantage: they have uncovered risks involved in managing all of the suppliers who engaged during their due diligence process. However, gaining this engagement and gathering this data from suppliers is not easy.

Think It’ll be Easy to get Your Suppliers to Engage on Conflict Minerals by Yourself? Think Again.

Article

Although nearly 1,300 public companies have filed with the SEC for Conflict Minerals compliance, over 95% of these companies said that they did not know the source of their 3TG (tin, tungsten, tantalum, and gold). The primary reason they filed “indeterminable” is because they could not get their suppliers to engage in the process. However, public companies will not be able to file “undeterminable” forever. And, the issue of suppliers either not knowing what to do, or not feeling compelled to do it – if they understood what to do – will remain.

Think It’ll be Easy to get Your Suppliers to Engage on Conflict Minerals by Yourself? Think Again.

Article

Although nearly 1,300 public companies have filed with the SEC for Conflict Minerals compliance, over 95% of these companies said that they did not know the source of their 3TG (tin, tungsten, tantalum, and gold). The primary reason they filed “indeterminable” is because they could not get their suppliers to engage in the process. However, public companies will not be able to file “undeterminable” forever. And, the issue of suppliers either not knowing what to do, or not feeling compelled to do it – if they understood what to do – will remain.

Kemet, Intel, Apple, HP Sets Best Example For Conflict Minerals

Article

Of the companies filing form SD and Conflict Mineral reports with the SEC this past Monday, a few raised the bar. Only a handful of these companies could declare “DRC Conflict Free” or “Portion DRC Conflict Free”. Even fewer, including Intel Corporation (INTC) and KEMET Corp. (KEM), conducted an Independent Private Sector Audit (IPSA) and named their auditor in the report. Apple and Hewlett-Packard also set positive examples, publishing full lists of suppliers and smelters, respectively. However, the vast majority of companies chose to file indeterminable.

Initial Conflict Minerals Filers Reluctant to be Transparent

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The deadline for public companies’ first disclosure to the SEC on conflict minerals arrived on Monday, June 2nd. The vast majority of filers are stating in their filings that they have not yet been able to determine the source of their tin, tantalum, tungsten, or gold (3TG).

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