Conflict Minerals: Everything You Need to Know and a Look Back at Kübler-Ross

One of our most popular articles over the last several years has been the Kubler-Ross model of environmental compliance.  With the recent passing of the final rules of the Dodd Frank provision on Conflict Minerals Assent has seen an influx of company’s transition through the various K-R Stages. Global companies like Apple and Intel have led the transition from Denial to Acceptance and have started making actionable strides to comply with the new requirements outlined by the SEC.

At Assent we have been assisting our clients through this process through the development of compliance plans, implementation of the Assent Compliance Suite to manage data gathering and analytics and performing end to end turnkey compliance programs. If your company is looking at conflict mineral compliance here are some resources we’ve assembled for you as well as a copy of our popular Kubler Ross post from several years ago.

Assent’s Most Recent Webinar:


• Introduction to Dodd-Frank Act Section 1502

• Requirements – Proposed Rules vs. Final Rules

• Assent Compliance involvement with Dodd-Frank Act

• Industry Approach

• Risks

• Steps to Compliance

• Final Rules Flowchart

• Timelines

• Assent Compliance Services

The SEC Final Rules:


Compliance Requirements Wizard:

OECD Guidance:

KR Post:

Assent Compliance global consultants have seen North American businesses react to conflict mineral compliance in a manner not unlike the Kubler-Ross grief model. The five company stages break down as follows:

1.       Denial – an outright denial by some companies to acknowledge that this regulation can affect them. While the majority of companies are beyond this stage, it’s still a prevalent sentiment—about 25 percent.

2.       Anger – any change from the status quo in a large organization may cause anger in those burdened with extra work. This can undoubtedly cause internal frustration with regard to means of compliance, budget decisions and plans for moving forward. During this early planning stage, companies have trouble making decisions and typically seek advice – about 30 percent.

3.       Bargaining – with any legislation there can be exemptions, addendums or clauses that may absolve a party of some portion of their responsibility. This is not typically the case for Conflict Minerals. Although the “bargaining”stage is not prevalent, it does occur in some companies – about 5 percent.

4.       Depression – typically a company will tender several requests for consultants to make suggestions and to better inform internal stakeholders on instituting a compliance process or system. Although this phase does not effect the organization as a whole, the compliance team itself frequently feels incapable of undertaking the task either due to perceived understaffing or adverse impact by their supply chain. This stage is more of a “micro” state, which follows the organization’s acceptance of REACH requirements – about 20 percent.

5.       Acceptance – once organizations accept the reality that environmental regulations are real, enforceable and can affect their bottom line, the typical response is an “Alright, let’s do it” approach – about 20 percent. As one Assent client noted: “Has our business model changed? No? If our business model includes selling our products globally then we’re going to comply with environmental regulations. It’s simple. We’re not afraid of challenges at this company.”

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