Conflict Minerals Compliance Basics: Supply Chain Tracability Auditing

In this instalment of “Conflcit Minerals Compliance Basics,” we will be going over supply chain tracability auditing. 

The law mandates the use of an "independent private sector auditor" to conduct the audits.  An audit must analyze the issuer’s due diligence framework from their Conflict Minerals Report to see that it conforms to the selected nationally or internationally recognized due diligence framework, such as The Organisation for Economic Co-operation and Development (OECD). The rule is unclear as to if the performance audit can be conducted through an internal audit function, but it appears to disallow such an audit. 

The rule requires that an issuer’s due diligence follow a nationally or internationally recognized due diligence framework, but there is only one such framework currently available, the OECD’s “Due Diligence Guidance for Responsibly Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.”

If your company has any questions regarding supply chain traceability auditing, send them to Source Intelligence’s help center.