Companies Unearth Few Answers on ‘Conflict Minerals’

In the next few weeks, some 6,000 U.S.-listed companies are expected to release lots of detail about their supply chains—but few conclusions—in the first reports required by law on whether their products contain “conflict minerals.”

 

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    • In it incorrect that compliance can be effortless with minimal expense. I guess we need to define “minimal”, but I would say my company has spend $300 – 400K and we re far from the answer …

    • Many companies experienced difficulties during the first year of Conflict Minerals understanding what the SEC was requiring and determining which of their products were in-scope for the regulation. That stage is now done. Beginning this year, companies are focusing on efficiently validating supplier data and moving their supply chains toward using audited, conflict-free smelters.

    • There are solutions that can make this compliance effortless with minimal expense. The SEC and NGO’s will not tolerate inaction.

    • Dramatically different regulations typically have a difficult first year – see S-Ox. For Conflict Minerals, many companies have taken the first year to let the dust settle, and there was plenty as described in the article. Year 2 will see more company investment, focusing on efficiently and effectively automating the conflict minerals reporting process.

    • Companies are wasting time and resources in attempting to comply. There is another SEC rule, Rule 12b-21, that says a company need not report any information that it does not possess and cannot obtain without unreasonable expense and effort. That is how every company should respond to the reporting requirement: “The information cannot be provided without undue effort and expense.”

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