Form SD for Conflict Minerals Compliance — Guide

Form SD for Conflict Minerals Compliance — Guide

With the May deadline for the first Conflict Mineral submission fast approaching, firms must complete their RCOI (reasonable country of origin inquiry) and have their form SD prepared in a relatively short period of time. Assent is currently working with over 100 firms to prepare the required documentation. In doing so we’ve outlined all the steps. Here is the entire process:

1. Form SD Creation

–    Disclosure of Conflict Minerals determination

–    Description of Reasonable Country of Origin methodology

–    Description of applied OECD Due Diligence standards

–    Description of applied Corrective Actions

–    Description of Conflict Minerals compliance process and plan

–    Disclosure of internet website address where this information can be accessed publically

2. Conflict Mineral Report Creation 

Conflict Minerals Determination

  1. DRC Conflict-Free
  2. Not “DRC Conflict-Free”
  3. DRC Conflict Undeterminable
  4. Product Determination based Audit and Certification Requirements
    1. DRC Conflict-Free:

–    Independent private sector audit of the Conflict Minerals Report

–    Certification of audit.

–    The audit report.

–    Identity of the auditor.

 

Not DRC Conflict-Free:

–    Independent private sector audit of the Conflict Minerals Report

–    Certification of audit.

–    The audit report.

–    Identity of the auditor.

–    The products manufactured or contracted to be manufactured that have been found to be Not “DRC Conflict Free.”

–    The facilities used to process the conflict minerals in those products.

–    The country of origin of the conflict minerals in those products.

–    The efforts to determine the mine or location of origin with the greatest possible specificity.

DRC Conflict Undeterminable:

–    Independent private sector audit of the Conflict Minerals Report

–    Certification of audit.

–    The audit report.

–    Identity of the auditor

–    Its products manufactured or contracted to be manufactured that are “DRC conflict undeterminable.”

–    The facilities used to process the conflict minerals in those products, if known.

–    The country of origin of the conflict minerals in those products, if known.

–    The efforts to determine the mine or location of origin with the greatest possible specificity.

–    The steps it has taken or will take, if any, since the end of the period covered in its most recent Conflict Minerals Report to mitigate the risk that its necessary conflict minerals benefit armed groups, including any steps to improve due diligence

Note on Description  of Due Diligence:

–    Application of OECD Due Diligence Framework

–    Establishment of a Strong Company Management Systems

–    Identification and Assessment of Risk in Supply Chain

–    Response to Identified Risks

–    Supply Chain Due Diligence reports

Here is the link to a sample Form SD template from the EICC: http://www.slideshare.net/EICCoalition/form-sd-template-draft

Does your firm need help with preparation of your Conflict Minerals Form SD? Contact Assent Compliance today. We have solutions for any sized company, ranging from Fortune 50 to SMB. info@assentcompliance.com 

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