It can also be helpful to know that a number of initiatives exist that may help your compliance efforts. The Government Accountability Office issued a report last year on “Global and In-region Supply Chain Initiatives,” which includes industry associations, multilateral organizations, and other stakeholders that have already developed programs and tools that may help your company and your suppliers comply with this rule.
The Securities and Exchange Commission emphasizes that these rules must be interpreted from primary texts and on a case by case basis, considering your company’s particular set of facts and circumstances.
Primary sources:
Dodd-Frank Wall Street Reform and Consumer Protection Act (2010), Sec. 1502 Conflict Minerals
www.gpo.gov/fdsys/pkg/PLAW-111publ203/pdf/PLAW-111publ203.pdf
S.E.C. Final Rule on Section 1502 of the Dodd-Frank Act
www.sec.gov/rules/final/2012/34-67716.pdf
Kirsten Wallerstedt is senior regulatory analyst, global supply chain, for 3E Company. Ms. Wallerstedt is presenting a webinar on this topic on April 17, 2013.
