Revenues from the mining of gold, tantalum, tin and tungsten — referred to as conflict minerals — in the Democratic Republic of Congo and surrounding countries may finance armed groups in the region. In response to this humanitarian issue, the US Securities and Exchange Commission (SEC) finalized a conflict minerals ruling in August 2012 that … Continue reading
I attended an invitation-only event today at the offices of Schulte Roth & Zabel on the topic of conflict minerals compliance. Speaking were Michael Littenberg of the Schulte Roth law firm and Kevin Hyams and Peter Manzetti of accounting, audit and assurance firm Friedman LLP. In attendance were about 12-15 corporate executives. I assume they represented their companies’ compliance departments … Continue reading
The Elm Consulting Group International LLC is preparing its Self-Implemented Conflict Minerals Audit Preparation© tool, or SICMAP℠, for a major update reflecting the upcoming final SEC regulations on conflict minerals. In addition, the tool will be renamed/rebranded to better reflect its use and scope. Upon its update and relaunch, it will be called the Conflict Minerals … Continue reading
Purpose of this Study The purpose of the study is to gather and share information that may be useful to the SEC’s rulemaking process and to industry. It aims to paint a picture of the costs and benefits of compliance with Dodd-Frank Section 1502 at the level of individual firms. This information is designed to … Continue reading
Some recent [in-region sourcing] developments include: The ICGLR’s Steering Committee for the Regional Initiative on the Illegal Exploitation of Natural Resources (RINR) has adopted the Certification Manual, thereby establishing the legal and political framework necessary for ICGLR Member States to start implementing their regional certification scheme. Efforts are underway to start issuing ICGLR regional certificates … Continue reading
8. Consider the impact of the regulatory environment on compliance programs and business plans. The increasing complexity of the global regulatory environment—including compliance challenges posed by the Foreign Corrupt Practices Act and the U.K. Bribery Act, the SEC’s whistleblower program, and Dodd-Frank provisions on conflict minerals and compensation clawbacks— will require continued attention. The right … Continue reading
In our view, the OECD framework (or perhaps more accurately, SEC’s possible incorporation of it into their final rules) may create more problems than it solves. According to Heim, the OECD may not amend the language of the guidance itself, but instead is amending the substance of the guidance through less formal “clarifications” from the … Continue reading
Traceability Provides Evidence of Conflict Free Minerals and Timber Legality Using raw materials from irresponsible sources can damage your brand and your profits. NGO’s like Change.org and Greenpeace are raising awareness of the environment and the cost of irresponsible sourcing: Mobile phones, laptops, digital cameras and jewelry have been associated with the use of conflict … Continue reading
As an industry leader in the compliance space, Enventure is one of the first companies to offer services to support companies that need to comply with the new regulation. The services are structured as comprehensive solutions, and are designed to reduce the additional work load on supply chain groups, brought on by the regulation. The … Continue reading
