Musings on Conflict Minerals Compliance – The Year That Was, the Year That May Be and What You Should be Doing Now

Jan 19, 2016 | Michael Littenberg
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With New Year’s behind us and roughly four and a half months to go until the calendar 2015 conflict minerals filings are due, many companies are ramping up their compliance efforts in earnest. In many respects, the drill has been and continues to be the same as for calendar 2014: determine in-scope products and suppliers, conduct supplier outreach, review supplier data and report. However, in other respects, there are notable differences between the two compliance cycles, including increased scrutiny by commercial customers and NGOs and more preparation and nervousness around the independent private sector audit requirement under the Conflict Minerals Rule. In addition, the last year has seen new supply chain compliance requirements, and EU regulation of conflict minerals is drawing closer.