Conflict Minerals Blog

Simplify Conflict Minerals Reporting -- Use Technology to Improve Collaboration

September 16, 2016
John R. Logan

Conflict Minerals Reporting is a collaborative effort.  A Company’s compliance program is typically led by an expert in product regulatory requirements who must work constructively with a network of professionals in different functional areas and from other companies.

Collaborative Workspace for Conflict Minerals™ leverages proven cloud technologies.  Combined with Green Status Pro’s professional services, Collaborative Workspace simplifies complying with the regulatory and auditability requirements of the Conflict Minerals Rule.  With an annual fee of $150 per user, Collaborative Workspace will pay for itself within days.

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Topics: Conflict Minerals

Engaging Recalcitrant Suppliers to Achieve Conflict Minerals Compliance

July 14, 2016
Rob Kasameyer

Are non-complying suppliers a major barrier to achieving your company’s Conflict Minerals Reporting objectives?  Unfortunately, many suppliers employ a variety of approaches which have been effective in enabling them to dodge the Conflict Minerals Reporting requirements. Engaging recalcitrant suppliers is the essential next step for improving your Conflict Minerals Reporting compliance. Green Status Pro recommends the following approach be taken going forward.

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Topics: Conflict Minerals

Don’t Bet Your Company on Conflict Minerals

June 13, 2016
Rob Kasameyer

Industry leaders are demanding their supply chains discontinue using smelters and refiners (SORs) that are not at least in the CFSP conflict-free audit process by the end of 2016. The risk to suppliers of ignoring this is significant: non-complying suppliers could lose their approved vendor status, forfeiting all new businessgoing forward. Betting your company on this risk makes no sense for rational suppliers.

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Topics: Conflict Minerals

Conflict Minerals Due Diligence Being Taken Seriously 2016

June 1, 2016
Rob Kasameyer

 

Apple, Boeing, Ford, General Motors, IBM, Intel, Microsoft, Signet Jewelers and other industry leaders are now acting to remove smelters and refiners (SORs) from their supply chain that are not going to be in the conflict-free audit process by the end of 2016. This action is severe, but not extreme: it is entirely consistent with Dodd-Frank Section 1502’s objective to support smelters that do not fund the conflict in the DRC region.

 

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Topics: Conflict Minerals

Qualcomm Lowers Conflict Minerals Risk with More Disclosure

May 18, 2016
Rob Kasameyer

Is it better to provide “too much” or “too little” information in the Conflict Minerals Disclosure (CMD) that your company will file with the SEC within the next two weeks? 

“Disclose as little as possible” is the immediate response of those who view Dodd-Frank 1502 as yet another regulatory liability. 

After reviewing Qualcomm’s CMD filed May 13, 2016, Green Status Pro suggests that greater disclosure actually lowers risk and increases company valuation. 

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Topics: Conflict Minerals

CMRT Version 4.10 Fully Supported by Green Status Pro

May 15, 2016
John R. Logan

Lexington, MA -- (ReleaseWire) -- 05/11/2016 -- Green Status Pro, the leading provider of Conflict Minerals Reporting services, demonstrated that it supports CMRT Version 4.10.  Version 4.10 was published on April 29, 2016, by the CFSI (Conflict-Free Sourcing Initiative.) 

Green Status Pro's CMRT Reporting Solution is the only technology that can extract and organize information directly from CMRTs.  This proprietary capability authenticates Smelter List entries against the CFSI Smelter Reference List, removes duplicate and invalid smelter entries, labels each smelter's current audit-participation status in the Conflict-Free Smelter Program, and extracts all Declaration statements.

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Topics: Conflict Minerals

Mandate for ALL Suppliers to SEC Filers: Get Your CMRT On Now!

May 2, 2016
John R. Logan

If your company has downstream customers covered by the US Conflict Minerals Rule, it must have an accurate, current CMRT (Conflict Mineral Reporting Template) in-place to support the 2016 sales effort.

Suppliers without a CMRT and those that have not completed one properly are now classified as Conflict Minerals Risks.  A company that is a “Conflict Minerals Risk” has little chance of being an “Approved Vendor” for long.

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Topics: Conflict Minerals

Warning: Conflict Minerals Reporting Malware Identified

January 21, 2016
Rob Kasameyer

The CFSI (Conflict-Free Sourcing Initiative) is the acknowledged authority on conflict mineral smelters and refiners. No other NGO has had the determination and capability to authenticate facilities and create a comparable 3TG smelter/refiner directory; no private company has published a credible listing of Conflict-Free smelters; trade associations focus on just one mineral and do not provide consistency across all four; the U.S. Department of Commerce has refused to take on this responsibility even though Dodd-Frank charged it with doing so.

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Topics: Conflict Minerals

February 9, 2016: the Next Conflict Minerals Deadline

January 6, 2016
Rob Kasameyer

The next critical milestone for Conflict Minerals Compliance is February 9, 2016. This date marks the 90-day deadline for the SEC to petition the US Supreme Court to review the D.C. Circuit Court of Appeals’ November 9, 2015, denial to rehear en banc a 3-judge panel’s divided August reaffirmation that “not been found to be DRC conflict free” is compelled speech that violates the First Amendment.

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Topics: Conflict Minerals

General Counsel -- December -- Conflict Minerals -- Must-Do

December 8, 2015
John R. Logan

Conflict Minerals reporting responsibility in multi-divisional corporations is typically owned by several individuals who are members of different functions and located in different offices around the world.

  1. What could possibly go wrong?
  2. Who will identify the problems?
  3. Who will implement the solution? When?
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Topics: Conflict Minerals