Conflict MineralsECD compliance can assist your organization with training and services for your conflict minerals supply chain assessment and disclosure requirements.

A provision for conflict minerals (tantalum, tin, gold, and tungsten) disclosure was included as section 1502 of the U.S. Dodd-Frank Act in 2010 and final rules were approved by the U.S. Securities and Exchange Commission (SEC) on August 22, 2012.

The disclosure rules are intended to provide public scrutiny to the chain of custody of 3TG metals (tantalum, tin, gold, and tungsten) used by manufacturers. In particular, organizations that are required to report under the SEC rules, must perform a "country of origin" inquiry on their use of such metals and report on whether the source of the metals are from mines that are funding conflict in the Democratic Republic of Congo. The first disclosure reports must be filed by May 31, 2014 (for the 2013 calendar year).

Organizations that do not have SEC reporting requirements may still be called upon by their customers (who may have SEC reporting obligations) to report their conflict mineral status.

The UN and the OECD have had special task groups assessing this situation for several years. In fact, the OECnt titleD produced a guidance documed "OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas" that highlights the need to control the supply chain through the smelters, which act as a pinch point for the industry. The GeSI and EICC industry associations have developed tools and smelter audit programs to assist manufacturers, but there have been numerous challenges in implementing these programs.

For training and assistance with your conflict minerals program, contact ECD Compliance.