Conflict minerals compliance, conflict minerals

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Risk and Compliance Magazine Hot Topic Q&A

Conflict minerals compliance and reporting

Risk and Compliance Magazine released a Q&A article featured in the fourth quarter 2015 issue that includes a "mini-panel" discussion on the current landscape of conflict minerals compliance and reporting. Deloitte & Touche LLP's Kristen Sullivan is one of the panelists featured in the article.

Questions discussed by the panelists quoted in the article include the following:

  • How would you describe the current conflict minerals compliance and reporting landscape? What are the main issues and challenges you have observed?
  • What impact has the influence exerted by NGOs had on the conflict minerals compliance and reporting landscape?
  • What advice would you give companies as they begin drafting their calendar year 2015 Form SD and conflict minerals reports in anticipation of a future independent private sector audit (IPSA)?
  • With the absence of a clear threshold for what ‘good’ looks like, in your view what does ‘non-compliance’ look like? And what should registrants be keeping in mind in terms of consequences of non-compliance?
  • How does the SEC’s Final Rule on Conflict Minerals impact the reporting and due diligence activities of private companies in the supply chain of end issuers’? How does this rule impact government contractors, if at all?

​Continued uncertainty is a good way to describe the current conflict minerals compliance and reporting landscape.

-Kristen Sullivan, Deloitte & Touche LLP

  • How do disclosure approaches differ across the various industries subject to reporting requirements? What advice can you offer to companies in certain industries that have limited ability to influence suppliers beyond direct suppliers?
  • Compared to Dodd-Frank Section 1502 and the SEC’s Final Rule on Conflict Minerals, how do you see requirements around conflict minerals compliance and reporting evolving worldwide? Are there opportunities for synergy in regulation around the world?
  • Do you expect the scope of conflict minerals reporting to change in the future? How can companies most effectively monitor ongoing compliance with changing expectations and evolving guidance around conflict minerals due diligence and reporting?

“Compliance with respect to conflict minerals can be viewed through many lenses–the SEC filing obligation, stakeholder expectations, company policy, and culture.”

-Kristen Sullivan, Deloitte & Touche LLP

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