Conflict Minerals Management: A Year Round Effort

Just three weeks after the second conflict minerals filing deadline, many companies are ready to sweep conflict minerals under the rug until next year, but should they?

Reporting year 2015 marks the third year of the Dodd-Frank 1502 law, and the first year supply chain scrutiny is increasing. Come this time next year, publicly traded companies will have to understand whether or not there are conflict minerals in their supply chain as the filing distinction “undeterminable” will no longer be an option.

The process of investigating one’s supply chain for conflict minerals requires significant effort. Under the law, publicly traded companies were allowed a two year grace period, meaning, they could file “undeterminable” and still stay compliant with the SEC. However, this year, the third year of reporting, the conflict minerals rule will go through distinct changes requiring companies to spend more time and effort on supply chain investigations.

In addition to increased scrutiny with the SEC starting in 2015, NGOs have also begun to look more closely at companies’ conflict minerals management. This year alone, just before the second filing deadline, Amnesty International/Global Witness and Responsible Sourcing Network, released two separate reports that evaluated companies efforts to eradicate conflict minerals from their supply chain. While the SEC requires companies to disclose whether or not conflict minerals exist in their supply chain, NGOs want a real win, non-conflict Tin, Tungsten, Tantalum and Gold sourcing from the Democratic Republic of the Congo.

Patricia Jurewicz, Andrew Arriaga from Responsible Sourcing Network and Tristan Mecham from Source Intelligence, recently discussed leading performance indicators developed to measure companies' conflict minerals reporting best practices in a webinar hosted by Source Intelligence. Responsible Sourcing Network guided viewers through the factors that led to their ratings on the "Indicators Shortlist: Measuring Performance in Conflict Minerals Reporting" report.

Even though companies filed with the SEC on June 1st, 2015, conflict minerals management is a continuous effort. If you are interested in learning about ways you can update your conflict minerals communication year round, check out the webinar available on Source Intelligence’s website.