Strategies for Conflict Minerals Compliance

On July 23rd, the D.C. District Court upheld the validity of the Securities & Exchange Commission’s (SEC) Conflict Minerals Rule, which requires companies to publicly disclose their use of conflict minerals that originated in the Democratic Republic of the Congo (DRC) or an adjoining country. All publicly-traded companies—including apparel manufacturers, retailers, importers and brands that manufacture or contract to manufacture products/private label merchandise—must comply with the rule. To comply, companies will have to perform reasonable country of origin inquiry, obtain information from their suppliers on conflict minerals (Tin, Tungsten, Tantalum and Gold or 3TG), and file their first report by May 31, 2014, to the SEC. It is also expected that private suppliers of public companies will have to implement programs to identify conflict minerals in their downstream supply chain. 

To ensure compliance, organizations will have to determine applicability, both at supplier and product level, perform supplier outreach, capture and analyze data, and prepare relevant reports for disclosure. If the company identifies that minerals have been obtained from the Democratic Republic of the Congo (DRC), organizations will also need to perform due-diligence and an independent private sector audit of the report to ensure compliance. Depending on the complexity of the supply chain and the number of products and suppliers, it’s no surprise that these tasks will require significant effort and time. 

In this webinar, Sonal Sinha, Associate Vice President Industry Solutions for MetricStream, an Associate Member of USFIA, and Dr. Ruud A. Overbeek, Vice President at Intertek, highlighted proven strategies and approaches for implementing conflict minerals compliance program. 

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