Conflict Minerals Compliance

CONFLICT MINERALS - Dodd-Frank Act, Sec 1502 – An Overview
In recent years, there has been an increasing international focus on “conflict minerals” emanating from mining operations in the Democratic Republic of the Congo (DRC) and adjoining countries. Armed groups engaged in mining operations in the Democratic Republic of Congo (DRC) and adjoining countries are believed to subject workers to serious human rights abuses and are using proceeds from the sale of conflict minerals to finance regional conflicts.

What is Dodd Frank Act Section 1502?
Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act aims at deterring through transparency of companies’ sourcing practices - the violence and human rights violations in the Democratic Republic of Congo (DRC) and neighboring countries, which are funded by the exploitation and trade of certain minerals. Section 1502 is a disclosure requirement that calls on companies to determine whether their products contain conflict minerals, and when applicable, by performing due diligence of their supply chain, followed by reporting to the Securities and Exchange Commission (SEC). 

Who is affected?
According to the SEC, an estimated 6,000 SEC-issuers and their supply chain, both publicly and privately held companies will be affected by Section 1502 of the Act.

Quick Facts

  • Conflict Minerals: Tantalum, Tin, Tungsten & Gold
  • First Reporting Deadline: May 31, 2014
  • Exemptions: Any material purchased or inventoried before January 31, 2013,/li>

What is required?
The SEC describes a three-step approach for Section 1502 disclosure

  • Determine whether compliance is required
  • Determine origin of conflict minerals and resulting disclosure
  • Report conflict minerals

Where do we start?
Are you seeking answer to this question when it comes to complying with the new U.S. regulation on conflict minerals? Connect with us to know how Acnovate can be your partner to build a complete conflict minerals compliance program that goes a long way to provide strong foundation for collaborative supply chain communication, risk & compliance management with faster ROI on time and cost.
How Can Acnovate Help?

Section 1502 of the Dodd-Frank Act was signed into law on July 21, 2010. SEC Issuers must provide disclosure under Conflict Mineral Provision if “Conflict Minerals (Tin, Tungsten, Tantalum & Gold) are necessary to the functionality or production of a product manufactured”.
Acnovate helps responsible manufacturers and their suppliers comply with Dodd-Frank conflict minerals regulation, respond to customer inquiries and demonstrate socially responsible supply chain practices. The risks posed to a business from Conflict Mineral requirements are significantly higher than regulations such as REACH and RoHS due to the submission of all information directly to the SEC and the disclosure of all compliance information to the public via a company’s website.

Acnovate provides clients with complete Conflict Minerals Compliance Suite as compared to do-it-yourself approach:

  • SEC’s Conflict Mineral Rule requirement determination
  • Reasonable Country of Origin Inquiry (RCOI) process setup
  • Conflict Mineral Compliance tool selection & implementation support
  • Supplier training & communication, response collection and follow-up
  • Report creation, 3rd party audit, due diligence measures and SD Form filing with SEC