Industry leader and conflict minerals bellwether Intel has filed its conflict minerals disclosure with SEC. Certainly we aren’t the first to break this news, although it seems this is still not as widely known as one may have expected.
We expect this to be viewed as a reference point for others to use, although few are likely to follow the lead entirely as Intel has put itself into a unique position relative to conflict minerals and has been highly proactive for more than four years.
Our main impressions of the filing:
- To no one’s surprise, it is far more than a minimalistic document, containing details and some metrics;
- Some products are classified as DRC Conflict Free and others as DRC Conflict Undeterminable – using the phrasing struck down by the Appellate Court;
- An IPSA was conducted and included in the filing as required for a DRC Conflict Free determination (we suggest everyone read the IPSA report to get a good understanding of what the IPSA entails, what is specifically excluded, and then assess the value of the IPSA in relation to potential cost);
- Intel’s definition of Due Diligence measures draws a clear line between RCOI and due diligence activities. This is done in large part by Intel defining due diligence in the manner Elm has advocated for some time (OECD Steps 3 and 4); and
- Smelters/refiners that are validated as Conflict Free by the CFSI are specifically identified by name and metal.