No Shortage of Questions Surrounding Due Diligence Compliance

There certainly was no shortage of questions during Source Intelligence’s Conflict Minerals: Industry Veterans Speak Out on the Changing Requirements of Due Diligence webinar. 

The following are samples of attendees questions: 

Q. When is the audit process required? What should I expect?

Answered by Dr. Jennifer Kraus, Chief Scientific Officer of Source Intelligence:

The audit process is only required when you find evidence within your supply chain of armed militia funding. Implementing and audit process will require the identification of resources – likely internal and external – to be able to effectively conduct an audit. Most companies are likely to have audit programs – whether for quality or regulatory compliance purposes. These same strategies and even audit tools can be applied to this purpose but obviously tailored to address the specific audit objectives for this type of work.

Q. If problems are discovered in the supply chain is there a required response?

Answered by Dr. Jennifer Kraus, Chief Scientific Officer of Source Intelligence:

A. This is a good question, because it made me think of something I don’t think we’re mentioned before. There are no specific requirements in the Final Rule. So, think about publishing a policy for responsible sourcing and that specifically addresses the supply of minerals from conflict areas. Give some thought to what you would do so that when something does happen you can rely on that policy to drive consistent and appropriate responses. If you do find concerns within your supply chain, on the one extreme you can immediately terminate the relationship with that supplier. But remember, depending on how far up and intertwined that supplier is with the rest of your suppliers that could be complicated. I’ll refer you back to the OECD guidelines. You may choose to provide your suppliers with an opportunity to mitigate within a certain amount of time. And that could be acceptable to your organization. There are no specific requirements in the Final Rule.

To receive the full list of questions or to listen to the Q&A portion of the webinar, visit: http://3bl.me/6z92na

If you have additional questions surrounding Due Diligence Compliance or the Final Rule, please submit inquiries to info@sourceintelligence.com and a Source Intelligence Team member will promptly respond.