Since 1998, more than 5 million people have died in the Democratic Republic of Congo as a result of armed conflict. The groups who continue to wage war are often financed by trade in “conflict minerals,” the rare and precious metals native to this region. If you’re an SEC registrant and your products contain these minerals, you’re now responsible for establishing due diligence across your supply chain to verify the country of origin and provide transparency of this information to the public. We can help you become compliant through our advisory support and outsourced services.approach
A Case for More Transparency
Commonly referred to as 3TG, Conflict Minerals include columbite-tantalite (tantalum), wolframite (tungsten), cassiterite (tin) and gold. All can be found in consumer products such as jewelry, mobile phones, computers, digital cameras and other electronics, as well as in other products as varied as packaging materials, pesticides, medical diagnostic equipment and zippers.
The goal of Dodd-Frank is to create the transparency to drive markets for conflict-free minerals. The SEC’s final ruling on Conflict Minerals (Dodd-Frank, Section 1502) requires a new level of supply chain transparency and affects public reporting for thousands of companies. Not only are SEC registrants directly impacted, but also their non-public company suppliers. If you manufacture any of the products or use any of the materials listed above, you’re likely subject to this regulation.
Regulatory compliance, including Conflict Minerals compliance, is a core competency for RGP.
Applicability, Due Diligence, Compliance
We have the supply chain expertise and cross-functional capabilities to ensure you meet all compliance requirements with minimal disruption and cost to your business. We follow a proven three-step process, which includes assessing your applicability, conducting due diligence and finalizing compliance reporting. The chart below lists the actions taken at each step.
Program Review and Assessment
As companies work to comply with the reporting requirements for Dodd-Frank Section 1502, they often encounter questions specific to Conflict Minerals:
- Did we satisfy the regulatory requirements?
- Are we in conformance with the OECD framework?
- Was our program reasonably designed and conducted in good faith?
- What are the gaps in our program and how do we remediate them?
- Do we have the work products to support the assertions in our filing?
- What actions are other companies outlining in their filing to improve due diligence and reduce risk?
- How do we compare with our peers?
To help answer these questions and prepare companies for compliance, RGP has developed a comprehensive Conflict Minerals Program Assessment as seen in the chart below.
Proven Compliance Methodology
During the past two years, RGP has completed numerous conflict minerals engagements and built a Center of Excellence to provide outsourced solutions for our clients. We have leveraged our proven conflict minerals methodology and have developed a modular and scalable solution for companies at various stages of conflict minerals compliance. The following chart shows the stages and range of our services.
policyIQ is our cloud-based document GRC solution. Powerful, flexible and easy to implement, policyIQ enables the focused management of a wide range of compliance processes, including Conflict Minerals compliance.