Supplier Conflict Minerals Disclosure Information and Reporting Law

J

jjhsuean

#1
I am not sure if I missed my search or else because I could not find anything related to the title unless this subject does not belong to here. I was trying to find out if anyone who is experienced can provide some guidance in completing the requirements that the customer impose on my company as a supplier for compliance.

The attached form is the basic/common reporting template for completing requesting, sharing and reporting supplier conflict minerals disclosure information. [Attachment: Conflict Minerals Reporting Template (EICCGeSIDDtemplate.xls) ]
 

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Stijloor

Staff member
Super Moderator
#2
I am not sure if I missed my search or else because I could not find anything related to the title unless this subject does not belong to here. I was trying to find out if anyone who is experienced can provide some guidance in completing the requirements that the customer impose on my company as a supplier for compliance.

The attached form is the basic/common reporting template for completing requesting, sharing and reporting supplier conflict minerals disclosure information. [Attachment: Conflict Minerals Reporting Template (EICCGeSIDDtemplate.xls) ]
Can someone help with this?

Thank you very much!!

Stijloor.
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#3
jjhsuean, Welcome to The Cove. DNV has a Business Unit that has a lot of experience with the Conflict Minerals subject in the supply Chain. Send me a private message with your contact information and I will put you in touch with the right people.
 

Kales Veggie

People: The Vital Few
#5
I am not sure if I missed my search or else because I could not find anything related to the title unless this subject does not belong to here. I was trying to find out if anyone who is experienced can provide some guidance in completing the requirements that the customer impose on my company as a supplier for compliance.

The attached form is the basic/common reporting template for completing requesting, sharing and reporting supplier conflict minerals disclosure information. [Attachment: Conflict Minerals Reporting Template (EICCGeSIDDtemplate.xls) ]
It is too soon. The SEC has not released its ruling.

You can contact me through my email if you need additional information. We offer services as well dealing with conflict minerals.
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#7
The SEC has not released its ruling.
According to this post in Triple Pundit, the ruling states:

When will companies have to file the information?

If companies determine that they do need to file a Conflict Mineral Report, the law says that companies will need to file their report on information gathered in the first full fiscal year after the rule is issued. So if a company’s fiscal year is Jan 1st – Dec 31st, the first report they will have to submit will be about fiscal year 2013 and they will submit it in early 2014. Some companies are encouraging the SEC to declare one calendar date when all companies will have to submit. This would make it easier for suppliers who have multiple customers filing to collect and distribute their information just once every year, rather than meet the timing of many different fiscal periods. In a consolidated industry such as the IT sector, it would be easiest for the entire industry to be asking for the information simultaneously. This might even motivate the unresponsive sub-sub-contractors to provide information.

Will companies have to report on 100% of the materials in their products in their first report? Many companies have been pushing for a “phase in” period, while many NGOs have been animatedly opposed. Last March in a House Appropriations Committee Hearing, Chairman Schapiro made reference to there being a phase in period for companies…. for how long, we are all looking for the rule to say.

If you are new to this topic and all of the above sounds overwhelming, do not despair! The electronics and telecommunications industries have already started verifying conflict-free smelters and there are a variety of industry-led and multi-stakeholder efforts underway such as the Public-Private Alliance for Responsible Mineral trade, a LinkedIn group, and an update call the first Thursday of every month hosted by the Responsible Sourcing Network. In regards to abiding by the new Conflict Mineral rule, take a lesson from EICC and GeSI, join together with your industry peers and associations to join existing efforts, or implement your own industry-wide accountability and traceability systems.
 
J

JaxQC

#8
Some quick notes to get you started.
· Note you may be exempt and not required to report independently if you do not file reports with the S.E.C. under the Exchange Act
· Look into House of Representatives bill H.R. 4173 §1502 Dodd-Frank Act for additional details.
o Specifically sections -838 thru 843
· Still unresolved issues and questions of delayed implementation by the SEC
o Technically they haven’t even gotten an officially released map defining exactly which countries are the ones affected.
 

Kimmy

Involved In Discussions
#9
Shoes,

We get 1 - 3 requests a week from our customers. We are a spring manufacturer, primarily for the automotive industry. We are trying to work with our vendors to gather the needed information but it is very slow going.
 

Buckyb

Involved In Discussions
#10
As a Boeing Supplier we recently received notice (Dec 6, 2012) that we are to "implement systems that allow supply chain transparency with regard to conflict minerals". We are not a publicly traded company, but we do supply product to a publicly traded company. Our intent is to, with due diligence, reach out to our suppliers to determine if conflict materials are present in any purchased product they provide which could then be in the product we send to the customer. We anticipate that we will provide guidance in our issued purchase order with a statement about conflict materials the same way we stipulate AS9100 7.4 requirements on our suppliers. Hopefully, this will satisfy the requirement.
 
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