This Year’s Conflict Minerals Filings Show Some Improvement, According to Early Review

Jun 22, 2015 | Cydney Posner
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An early review of conflict minerals filings for the 2014 reporting period shows improvement in “detail, clarity and quality,” according to this article in BNA. As reported by Elm Sustainability Partners, a conflict minerals consulting firm, there were 1,272 filers for the 2014 reporting period, compared to 1,328 for 2013. In addition, Elm reported that there were six independent private sector audits (IPSAs). In the article, commentators remarked that “the submissions this year are more clearly written, align better with the Organization for Economic Cooperation and Development framework and list more smelters.”  Having access to the reports filed by other issuers probably provided helpful guidance and added some measure of consistency to the reports. BNA also found that a number of companies reported sourcing gold from North Korea, which is on the Treasury Department’s sanctions list.

Responsible Sourcing Network, an NGO, reported an increase in the percentage of companies that filed conflict minerals reports (not just the more abbreviated Form SD), relative to the prior year. An RSN representative also agreed that this year saw improved disclosure: “Overall there are more detailed filings, with a higher ratio of filers submitting a full report on their due diligence process.”  According to the article, RSN intends to advise investors on the level of performance by companies in “high-exposure industries,” based on RSN’s performance metrics. (See the 2015 list of indicators.)