Is my company affected by the SEC's conflict minerals rules?
Probably yes. As long as you are a direct or indirect supplier to a company that files certain reports with the SEC, you may be asked to provide information regarding the uses and sources of conflict minerals in your products.
Is it illegal for my company to use conflict minerals?
No. The law only requires that you disclose your sources. Severing ties completely with the metal-rich Democratic Republic of Congo would ultimately lead to its economic collapse. Instead, the SEC wants to verify that the tin, tantalum, tungsten, and gold that gilds sealants, seat cushions, circuits, and sensors isn't coming from warlord-run mines.
Does my company need to develop a conflict minerals policy?
It varies. And it depends on a myriad of factors, like your customer base and the complexity of your supply chain. We encourage you to seek legal guidance when considering these kinds of decisions.
Click here for all of these and more. To kick-start your compliance efforts, hit the button below.
Image credit: Ariel Schwartz