One of the more common questions we hear from companies on the topic of conflict minerals is “Are we behind the curve?”
Every company faces their own challenges in understanding the requirments, assessing their needs and implementing programmatic changes. But there are a number of common guideposts that provide reasonable indications on general progress – and shed light on whether your company is falling behind.
So, in an unabashed take-off of Jeff Foxworthy’s “You Might be a Redneck If…”, we offer the following. If any of these sound familiar, then it is probably time to pick up the pace. Second quarter is fast approaching and one consistent trend has emerged for companies who are immersed in this right now – this process takes more time, and is more complex, than it seems. It is valuable to ensure you have as much time as possible in 2013 to make key decisions, gather data and develop processes to support SEC reporting or customer information requests.
You might be falling behind on conflict minerals if…
You had not heard the term “conflict minerals” before the first of this year.
Customer information requests on conflict minerals are piling up unanswered.
Your company has not established an internal conflict minerals team, or assigned formal leadership responsibility to look into the matter.
Consultant proposals for conflict minerals support are sitting on your desk that have not been reviewed or approved.
You don’t have at least a general sense about the range of your company’s products that contain conflict minerals.
You are not certain if existing information management systems can link specific suppliers through your manufacturing processes to a final product.
You think that you don’t need anything more than a spreadsheet or IT system to solve this problem.
You haven’t read the SEC regulation, the OECD Due Diligence Framework and at least one White Paper or Client Alert from a law firm or consultant.
You have not identified or assessed what gaps may exist between the SEC regulation, OECD Framework, customer requirements and your existing internal management systems.
You have not attended at least one conference or webinar on the topic (free webinars are offered practically weekly).
You have not notified your suppliers that you will soon be contacting them for more information about the products they supply you.
You don’t know how you will contact suppliers to gather relevant conflict minerals information.
You don’t know what your industry associations are doing relative to conflict minerals.
The company’s strategy is hoping the issue goes away.
We are available to help with any questions.