Conflict minerals: compliance considerations for private companies

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1 Conflict minerals: compliance considerations for private companies Version October 2014 Conflict minerals: compliance considerations for private companies As a result of the Securities and Exchange Commission s (SEC) final rule on Section 1502 of the Dodd- Frank Wall Street Reform and Consumer Protection Act (the Final Rule ), private companies not legally subject to the Final Rule s reporting requirements are still impacted. Many private companies in the supply chain of registrants find themselves obligated to put in place a conflict minerals compliance program to enable credible and reliable reporting to meet commercial requirements of their s. Specifically, many private companies that are suppliers to registrants are receiving requests from these s to investigate their supply chain and provide information regarding the use of conflict minerals 1 in the products they sell. What does this mean for private companies? Bottom line doing nothing may not be an option. As registrants subject to the Final Rule continue to gain greater insight and visibility into their supply chain procurement practices, they will increase their ability to take actions against non-compliant suppliers. Suppliers that do not comply with registrant information requests and other forms of engagement may find themselves at risk of being replaced by other suppliers. Impacted registrants will increasingly be held accountable for the performance of their conflict minerals compliance program performance and thus will increase the pressure on their suppliers to do the same. As the marketplace attention around conflict minerals continues to evolve, so too will expectations for greater transparency around broader supply chain risk management practices. As companies look to develop more comprehensive and integrated approaches to supply chain compliance activities and disclosure practices, suppliers including private companies will be looked to for information on their own supply chain. Integrating conflict minerals compliance program with other supply chain compliance activities (e.g., Foreign Corrupt Practices Act (FCPA), Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), Restriction of Hazardous Substances (RoHS), etc.) can leverage potential efficiencies and proactively get in front of new regulations. 1 (A) Columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted) or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (DRC) or an adjoining country

2 Overcoming private company challenges Private companies in the conflict minerals supply chain of impacted registrants face unique challenges. As registrants look to improve their due diligence process in Year 2, private companies will likely be faced with challenges in meeting the increasing commercial expectations of their s. Private company challenges Resource constraints While many private companies recognize that conflict minerals compliance, like many other requirements, will become table stakes for doing business with registrant s, conflict minerals compliance activities were, in many cases, not top of mind during a private company s budget process in Year 1. Building the business case to identify the resources necessary to execute a private company s conflict minerals compliance efforts remains challenging in this uncertain environment. Many private companies are beginning by layering the responsibilities of conflict minerals compliance activities onto various existing employees workloads. A conflict minerals technology solution can increase efficiencies in complying with commercial expectations for reporting necessary data related to conflict minerals compliance. A private company may not be ready to invest in a technology solution, and in many cases will begin by initiating and tracking supplier surveys manually. In some cases, private companies have looked to tailor existing internal systems to support conflict minerals data tracking. Understanding the Final Rule Responding to inquiries While some private companies initially took the position that they did not need to consider the requirements of the Final Rule because they were not a registrant, the onset of requests triggered for many the recognition that private companies were in fact swept up into the conflict minerals compliance activities of many impacted registrants. Having not followed the Final Rule requirements from the start, many private companies found it daunting to understand and to determine where to begin. Many registrants provided, and continue to provide, resources to their suppliers in the form of live trainings and online resources to aide in the understanding of the Final Rule and the expectations the registrant has of its suppliers. Private companies are not legally obligated to submit a filing to the SEC under the Final Rule; however, private companies increasingly need to understand the expectations of registrant s. While most registrant s have initiated the conflict minerals information request through the Conflict Minerals Reporting Template (CMRT), developed and maintained by the Conflict Free Smelter Initiative (CFSI), others have requested specific information (e.g., part numbers, parts supplied that contain conflict minerals, etc.) beyond the standard data collection format established by the CMRT. The CMRT provides a standard data collection and reporting template to facilitate conflict minerals information collection from suppliers. Additionally, the CMRT includes a list of known smelter and refiner names to assist registrant s and suppliers in identifying actual smelters and refiners. Regardless of the mechanism used to respond to registrant s, private companies should undertake measures to thoroughly evaluate the responses received from its upstream suppliers and translate that information to its own CMRT to be responsive to its requests. 2

3 Making conflict minerals a value proposition Executive-level support is a critical step in implementing an effective conflict minerals compliance program. In order to secure a broad level of support within a private company, the value of such a compliance program to the organization must be clearly defined and articulated. The value proposition in the case of a conflict minerals compliance program for a private company will, in many cases, be a function of the expectations established by the company s registrant s. The degree to which compliance with commercial expectations, increasingly established through contractual terms, directly impacts the commercial relationship with a registrant within a certain timeframe will drive prioritization in the context of budgetary restrictions, lack of personnel, and the general attitude that it is not a requirement for private companies. And private companies can often find value when looking at conflict minerals compliance in a more holistic view toward integrating activities around multiple supply chain transparency and compliance requirements, including the following: 3

4 Getting started While each company s situation is different, getting a conflict minerals compliance program off the ground typically involves a few key activities, including creating a cross-functional team to bring together the affected areas of the business with respect to conflict minerals compliance and becoming familiar with the OECD Framework 2 to understand the framework that registrants will design their due diligence programs to conform to, and thus will drive expectations of their suppliers. Additionally, by reporting the conflict minerals compliance program within the corporate sustainability report, the company can take credit for its actions and convey to its stakeholders its intentions. Get executive buy-in and find the budget Understand requirements Understand the supply base and product lines affected Use the CMRT to survey suppliers and employ the OECD Framework in performing necessary due diligence Translate survey results into the CMRT to respond to requests Report the conflict minerals compliance program within the corporate sustainability report As marketplace expectations continue to evolve in this area, so too will the requests and expectations of registrants s regarding a company s conflict minerals program. Understanding that a conflict minerals compliance program can generate benefits for the company in other areas of the supply chain, relationships with s, maintaining business, and brand recognition can make undertaking a comprehensive conflict minerals compliance program more value added. 2 Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition 4

5 Contacts For more information, please contact Kristen Sullivan Partner Donald Fields Director Jeff Torstenson Director This document contains general information only and Deloitte is not, by means of this document, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This document is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional advisor. Deloitte shall not be responsible for any loss sustained by any person who relies on this document. About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee ( DTTL ), its network of member firms, and their related entities. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as Deloitte Global ) does not provide services to clients. Please see for a detailed description of DTTL and its member firms. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting. Copyright 2014 Deloitte Development LLC. All rights reserved. Member of Deloitte Touche Tohmatsu Limited 5

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