In 2010, Congress passed the Dodd-Frank Act, which requires companies to disclose their use of conflict minerals. Under the Act, those minerals include columbite-tantalite (coltan), casserite, gold, wolframite, tantalum, tin, and tungsten and any other mineral determined by the U.S. Secretary of State. Companies must exercise due diligence on the source and chain of custody of their conflict minerals that conforms to a nationally or internationally recognized framework, such as the one approved by the Organization for Economic Co-operation and Development (OECD). The Conflict Minerals Report will be filed under the Securities Exchange Act of 1934 as an exhibit to Form SD, subjecting the company to potential liability. The effective date for filing is May 31 every year. Keep in mind that his year – May 31st falls on a Sunday and companies will have until Monday, June 1st to file.
Failure to file or to achieve compliance with the Conflict Minerals Regulations will draw scrutiny from the SEC and the GAO and activist groups and could call into question your corporate and social responsibility programs. You may miss this year’s filing date but it is never too early to start thinking about next year! And more importantly, it’s never too early to do the right thing and ensure your supply chain is steering clear of any conflict minerals.
Let Lavante do the heavy-lifting, ensuring continuous compliance, while protecting your reputation and maintaining corporate social responsibility. You’ll no longer need to rely on consultants with Lavante’s scalable and affordable solution. Our application drives your suppliers to an online Conflict Minerals Reporting Template (CMRT) and guides them through the completion process. We offer:
- Real time dashboarding of your suppliers’ progress against the CMRT
- E-signature attestation by suppliers (wherever necessary)
- Rapid deployment in 2 to 3 weeks to meet the SEC’s deadline
- Configurable formatting and exporting for subsequent reporting.