Conflict Minerals Blog

Simplify Conflict Minerals Reporting -- Use Technology to Improve Collaboration

Posted: September 16, 2016 Submitted by John R. Logan

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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.

To meet the regulatory obligations of Dodd-Frank Section 1502, the head of Conflict Minerals Reporting must work with:

  1. Suppliers: The goal is to obtain a properly completed CMRT from every relevant supplier. If such a CMRT is not available, due diligence follow-up is required.  After the CMRT-collection phase is completed, Customers are working with their Suppliers to remove smelters from the supply chain that are not participating in the CFSP audit protocol program.
  2. Procurement: Account executives are responsible for either obtaining an accurate CMRT from the suppliers they buy from or removing them from the Approved Vendor category. Close collaboration between a Company’s Procurement executives and Conflict Minerals professionals is necessary when working with a Supplier that refuses to participate.
  3. Customers: Collaboration facilitates trust that a Supplier is delivering both an accurate CMRT AND that all smelters not participating in the CFSP audit program are being transitioned out of the supply chain ASAP.
  4. Engineering and Procurement: At the beginning of the Conflict Minerals Reporting effort, the Engineering and Procurement organizations must jointly identify which components contain 3TGs and who the suppliers are. At the conclusion, with the assistance of the Company’s Conflict Minerals professionals, these same two departments must act to remove Suppliers from their supply chain that refuse to participate constructively in the Conflict Minerals Reporting effort.
  5. Corporate Staff: At a minimum, Legal, Audit, Media Communications and Investor Relations, will demand evidence that the company’s RCOI (Reasonable Country of Origin Inquiry) was correctly conducted before making the information public or allowing a senior executive to sign-off on Form SD.

To add to the complexity of the Conflict Minerals Reporting effort, documenting both the work effort procedures and results is mandatory.  Documentation is critical for SEC-registrants who must annually file Form SD describing the RCOI they conducted.  In addition, most are preparing to undergo the potential independent private sector audit (IPSA) that is required by Dodd-Frank Section 1502.

Green Status Pro is a conflict minerals specialist that combines technology and service to support our Clients.  Green Status Pro’s Ingestor™ is the leading technology for processing CMRT reporting forms.  Now Green Status Pro has combined technology and process to significantly improve our Clients’ collaboration and documentation capabilities.

Collaborative Workspace for Conflict Mineralsleverages 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.

Conflict Minerals professionals gain the advantages that:

  1. All their Conflict Minerals data and electronics communications is stored in one central repository. Data will never be misplaced!
  2. The intuitive interface allows users to increase their productivity starting Day One.
  3. Data can be accessed with smartphones and tablets – it releases users from their desktop PCs.
  4. The collaborative functionality is extremely powerful.
  5. It is highly secure. Data is encrypted both when transmitted and stored.  Data is backed-up and mirrored.  All transactions are logged.  Access is password protected and two-step verification is available.  Each client has its own dedicated database.
  6. Collaborative Workspace is affordable. The annual fee is $150 per user.

To learn more, watch the short video at https://youtu.be/2ItPyxx1Q4I, visit the web page, or contact me directly at john.logan@greenstatuspro.com.

Green Status Pro specializes in delivering the expertise and services required for corporations to meet the regulatory and customer mandates of Dodd-Frank Section 1502 and the SEC. We will cost effectively work with you to gather and analyze the required conflict minerals data, delivering essential reports on a timely basis, as well as providing critical support services to meet customer requests as required throughout the year. Green Status Pro will assist you in meeting your customers’ requirements for 100% accurate CMRT Smelter List V4.10 and delivering the comprehensive RCOI reports required by Dodd-Frank Section 1502.

 

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Topics: Conflict Minerals