QUESTION: Where in the Regs does it explicitly state that I am to publish my Conflict Minerals Report on my company’s website? I don’t see it in 17 CFR § 240.13p-1. ************** Answers: You do not have to publish your CMRT on your website. As a downstream supplier, you will be asked for your report a […]
QUESTION: We are a publicly traded company that is subject to the Conflict Minerals provisions of section 1502 of the Dodd-Frank Act. Section 1502 requires all companies listed on U.S. stock exchanges to trace the minerals used in their supply chains and declare whether they are conflict-free. “Conflict-free” means that companies can prove that the […]
QUESTION: As a private company, are we obligated to solicit information from our suppliers on conflict minerals? We supply public companies and therefore receive solicitation requests from them. I am just wondering if we need to use the full Electronic Industry Citizenship Coalition (EICC) solicitation template or a shortened version. Any guidance would be appreciated. […]
Question: What is the memberships experience with the level of due diligence their companies are doing with regards to conflict minerals? Specifically, how far back in the supply chain is your company querying to determine the conflict mineral status of the items procured? Do your companies only query their 1st tier supplier base or do […]
Question: We are trying to figure out where the conflict minerals investigation and reporting responsibility would be better served. Can members please advise where this reporting requirement falls within your company? Some typical options include: Legal Sourcing/Procurement Trade Compliance Ethics & Compliance Regulatory Compliance Engineering Other ================ ANSWERS: It’s under Regulatory & Compliance in […]
Question: I have recently been assigned Conflict Minerals to go along with my other traditional trade compliance duties. As this is relatively a “new” field to compliance, I am asking the membership for any processes, procedures and the like they would be willing to share regarding how they go about collecting, auditing and providing information […]
