Conflict Minerals “Undeterminable”, the New Norm?

June 1, 2015 will be the second time publicly traded companies will be required to file their conflict minerals reports (CMRs) with the SEC. Enacted in 2010, Dodd-Frank 1502, a regulation with the goal to minimize minerals produced and refined under conflict, requires companies to disclose the origin of tin, tungsten, tantalum and gold (3TG) in their supply chains.

What is different about conflict minerals reporting in 2015 than the first year of Dodd-Frank 1502? Not much, actually. If you filed undeterminable last year, you can still do so this year again. However, many companies are realizing the magnitude of work that goes into investigating their supply chains and have started to prepare for reporting in 2016, the first year of reporting where companies will no longer be able to file “undeterminable”. Reporting in 2016 also brings on a new level of scrutiny as companies will likely be required to complete an independent private sector audit (IPSA) and submit a copy of that report along with their filings.  

If you are interested in seeing who has filed conflict minerals reports with the SEC so that you can better understand how to shape your report, Source Intelligence is offering a weekly alert until the reporting deadline.

Remember, utilize 2015 reporting year to understand your own due diligence gaps and risks so you are well prepared for reporting in 2016.