The Elm Consulting Group International LLC (“Elm”) will deliver independent third-party Conflict Minerals Supply Chain Traceability Audit services aligned with the SEC mandates for auditor independence to companies across the range of industries impacted by the US Conflict Minerals Law, enacted as part of the Dodd-Frank Wall Street Reform Act.
In 2010, Elm was engaged by a leading US-based electronics manufacturer industry association to conduct the first independent third-party Conflict Minerals supply chain traceability audits supporting the association’s “Conflict Free Smelter” designation for tantalum. Those audits were the first of their kind, resulted in the first “Conflict Free Smelter” designations issued, and generated significant improvements to the initial audit tools/scope created by other stakeholders.
Patrick Doyle, Managing Director in Elm’s New Haven, CT office: “Elm is a world leader in conducting Conflict Minerals supply chain traceability audits to support the new Conflict Minerals Law in the U.S. We saw significant value in bringing our experience to assist a broad range of industries and companies. However, we were concerned about potential conflicts of interest with being engaged by a trade association consisting of multiple corporate members that also may have relationships with other Elm clients. In our 2011 strategic planning, we decided to withdraw from our relationship with the association and eliminate the conflict of interest risk for them, their members and Elm. The association will continue to move forward using other available resources, so our withdrawal will not negatively impact their program.”
Lawrence Heim, Director of Elm in Atlanta, Georgia: “The US Conflict Minerals Law empowers the SEC with authority for the law’s oversight and enforcement. Therefore, related audit activities will be subject to audit standards under the SEC, the Government Accounting Office Government Accounting Standards (GAO GAS) and American Institute of Certified Public Accountants (AICPA) Statements on Standards for Attestation Engagements (SSAE). Eliminating auditor conflict of interest is absolutely critical for conflict mineral reviews/audits. SEC’s December 15, 2010 proposed regulation gave specific direction on this. We don’t feel this will change even with the extension of the comment period and possible delay in the finalization of the rule.”
Heim continued, “We are hearing from some companies that internal procurement standards are already mandating that material be purchased only from sources that have been audited and verified by independent third parties as ‘conflict free'”.
Since its inception in 2001, Elm has focused its business on independent health, safety and environmental auditing services. “Conforming to the SEC auditing standards does not require us to do anything significantly different from our long-standing processes and procedures,” Doyle stated.