Tag Archives: Conflict Minerals

Conflict Minerals Questions Answered

Sheena Moore - May 10, 2013 1:25 PM | Categories: Commentary

Where do US manufacturers stand on conflict minerals compliance as we approach 2H2013? At Conflict Minerals EDGE earlier this week, we sought to find out. We’re proud to share some audience takeaways:    

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Conflict Minerals Analysis: Readiness, Technology and Questionable Practices

Jason Busch - May 8, 2013 2:55 PM | Categories: Commentary

In this analysis, Lisa Reisman summarizes the key takeaways and compliance recommendations from the Spend Matters/MetalMiner event: Conflict Minerals EDGE. How prepared are most companies to tackle conflict minerals compliance based on what you heard and saw? One point that I came away with was that many companies have greater capability than they think to pursue conflict minerals compliance initiatives. For example, if you’re in pharmaceutical or aerospace, you’re likely doing part or lot level traceability already. Some companies might be able to piggy-pack on these initiatives. The audience was a self-selecting bunch of over 50 from the manufacturing world [...]

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Conflict Minerals Q&A: SEC Enforcement, China, Scrap, and Supplier Views

Jason Busch - May 7, 2013 3:08 PM | Categories: Commentary

This Spend Matters PRO series is based on commentary and opinions expressed by the following industry experts at the MetalMiner/Spend Matters Conflict Minerals EDGE event: Jennifer Diggins (Nucor), Jeff Friedman (Kloeckner Metals), Lawrence Heim (The Elm Consulting Group), Rose of Sharon DeVos (Stainless Sales Corporation), Michael Pfeifer (Industrial Metallurgists LLC), Michael Loch (Motorola Solutions), Michael Littenberg (Schulte, Roth & Zabel), Chris Grove (Commerce Resources), Tyler Showalter (Buffalo Tungsten), Michael Loch (Motorola Solutions) and Dan Kendall (ABC Metals). Is the SEC prepared to enforce conflict minerals compliance? The SEC did not get approval to enforce conflict minerals (headcount wise) despite the fact [...]

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Conflict Minerals EDGE: Compliance Technology (Part 3)

Jason Busch - May 7, 2013 10:03 AM | Categories: Commentary

This post is based on content delivered during Conflict Minerals EDGE. It leverages content contained in presentation delivered by Spend Matters Thomas Kase titled: Conflict Minerals: Let Technology Do The Heavy Lifting. Spend Matters PRO subscribers (annual full subscribers or corporate members) can request a copy of the presentation by dropping us a line. Universal automation steps for Conflict Minerals compliance include leveraging various standardized tools— such as the Conflict Minerals CheckPoint Reference spreadsheet (contact us for more information on it)—for data capture, management, auditing, using Reasonable Country of Origin Inquiry (RCOI), and adherence to OECD’s 5-Step Due Diligence Framework. [...]

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Conflict Minerals EDGE: Compliance Technology (Part 2)

Jason Busch - May 7, 2013 8:06 AM | Categories: Commentary

This post is based on content delivered during Conflict Minerals EDGE. It leverages content contained in presentation delivered by Spend Matters Thomas Kase titled: Conflict Minerals: Let Technology Do The Heavy Lifting. Spend Matters PRO subscribers (annual full subscribers or corporate members) can request a copy of the presentation by dropping us a line. There is a hidden benefit to using technology to drive external conflict minerals compliance. The same solutions that engage with external parties to ensure that they have understood and accepted the 3T/G requirements – plus counter-signed company policies – can work for internal users at all [...]

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Conflict Minerals EDGE: Compliance Technology (Part 1)

Jason Busch - May 6, 2013 2:28 PM | Categories: Commentary

This post is based on content delivered during Conflict Minerals EDGE. It leverages content contained in presentation delivered by Spend Matters Thomas Kase titled: Conflict Minerals: Let Technology Do The Heavy Lifting. Spend Matters PRO subscribers (annual full subscribers or corporate members) can download the entire presentation here. Spend Matters and MetalMiner research suggests that technology should be key in assessing and managing conflict minerals compliance. But the landscape – and noise generated by a number of providers – can be quite confusing. Thomas Kase shared during his presentation today that there are several categories and classes of solution that [...]

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Conflict Minerals EDGE: Steel, Stainless Steel, and Distribution Roundtable

Sheena Moore - May 6, 2013 1:00 PM | Categories: Commentary

Moderator Lisa Reisman (MetalMiner) takes the stage with Jennifer Diggins (Nucor), Jeffrey Friedman (Kloeckner Metals), Rose of Sharon DeVos (Stainless Sales Corporation), Michael Pfeifer (Industrial Metallurgists, LLC), and Lawrence Heim (The Elm Consulting Group) to kick off the afternoon session of Conflict Minerals EDGE. (Click image to enlarge)

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Conflict Minerals EDGE: Compliance and Auditing Strategy

Jason Busch - May 6, 2013 10:01 AM | Categories: Commentary

Compliance audits will undoubtedly form a critical component of overall compliance strategies for companies that most document traceability and compliance in their supply chain for conflict minerals compliance. But how far should compliance audits go? Earlier today, Lawrence Heim (Director of The Elm Consulting Group International) suggested that audits should consider traceability and attest down to the mine-site level. This includes chain of custody, refiners/smelters and manufacturing suppliers in the supply chain (e.g., tier 3 semi-finished material supplier; tier 2 parts suppliers; tier 1 component suppliers) as well as at the OEM manufacturing level itself. For auditing, SEC regulations clearly [...]

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Conflict Minerals EDGE: Corporate Policy and Compliance Philosophy

Jason Busch - May 6, 2013 9:25 AM | Categories: Commentary

This morning, Lawrence Heim (Director of The Elm Consulting Group International) suggested three foundational conflict minerals compliance efforts to consider: Setting corporate policy Product assessments/product reviews Defining supplier engagement We’ll focus our coverage on Lawrence’s views on setting corporate policy for conflict minerals compliance. For overall corporate policy, Lawrence suggests remembering that compliance policy requires far more than just putting general concepts and plans on paper. Corporate policy forms the foundation of the program’s scope, execution, and ultimate audits. Establishing corporate philosophy is a key element. For example, are you going to pursue, a completely DRC-free strategy? Or a DRC [...]

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Conflict Minerals EDGE: “Just Say No” to Conflict Minerals Outsourcing

Jason Busch - May 6, 2013 8:44 AM | Categories: Commentary

Lawrence Heim, Director of The Elm Consulting Group International, came out with a strong statement that those tasked with conflict minerals compliance should consider as early as possible in developing their compliance policy: “Just say no” to complete outsourcing approaches. Lawrence suggests that he does “not personally recommend outsourcing all elements of Conflict Minerals compliance” to a third party. He says, “We are on the line. We have to face customers. We have to address concerns of suppliers. If we’re going to think about having a third-party take responsibility, just consider the fact that it is not beneficial to pursue [...]

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Conflict Minerals EDGE: Compliance 101 (Part 1)

Jason Busch - May 6, 2013 7:47 AM | Categories: Commentary

Lawrence Heim, Director of The Elm Consulting Group International, kicked off Conflict Minerals EDGE with a presentation exploring practical strategies and approaches for conflict minerals compliance. He began by suggesting the importance of having a strategy that mirrors what your customers have to deal with (for those not at the highest levels of the supply chain already). Even if you’re not directly impacted by regulations in terms of your own SEC reporting, you will be based on the requirements for traceability in the supply chain. You need to think like your customers. In other words, if you’re involved in any [...]

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Conflict Minerals EDGE Live!

Jason Busch - May 6, 2013 5:51 AM | Categories: Commentary

confedge Spend Matters and MetalMiner are hosting our first event of 2013 today in downtown Chicago: Conflict Minerals EDGE. In considering the conference production textbook, we did pretty much everything wrong: We decided to hold Conflict Minerals EDGE because we were intellectually interested in the topic and saw a pragmatic business need to cover the subject matter live (not because of a pro-forma P&L that showed we’d make a few bucks on this) We came up with the idea less than three months before the event We announced it and went about getting speakers, sponsors and attendees (not necessarily in that [...]

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Compliance Approaches: Our Survey Results and Analysis

Jason Busch - May 2, 2013 8:16 AM | Categories: Commentary

Before Conflict Minerals (for its traceability and compliance requirements, see The Definitive Guide to Conflict Minerals Compliance for Manufacturers), REACH and RoHS supply chain compliance approaches were perhaps the best gauge for which types of programs procurement and operations teams would put into place to manage traceability. In an earlier survey on the subject, we found that only 3% of companies had put in place a system to collect, handle and validate “REACH and RoHS compliance on a product and supplier level.” In contrast, 35% of respondents relied on the non-audited sign-off of “suppliers providing agreements that they comply with [...]

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Upstream Risk Mitigation and Logistics/Transit Routes

Jason Busch - April 29, 2013 8:01 AM | Categories: Procurement Research

The following post is based on material contained in the MetalMiner report (available for free download): Conflict Minerals: Building Responsible Manufacturing Supply Chains. Join MetalMiner and Spend Matters for the Conflict Minerals Edge event taking place on May 6th in Chicago. Upstream Risk Mitigation Following the clarification on information needs from upstream actors, OECD also acknowledged “that upstream suppliers are those who can most effectively and most directly mitigate the risks of adverse impacts. Downstream companies are not expected to directly mitigate risks upstream in the supply chain” and that “industry initiatives provide one-way information on upstream activities and add [...]

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Conflict Minerals – Dodd-Frank, Section 1502

Thomas Kase - April 25, 2013 10:02 AM | Categories: Commentary

The following is a preview from Thomas Kase’s upcoming presentation at Conflict Minerals EDGE, on May 6 at Hotel Sax Chicago. It’s not too late to register – we hope to see you there! Within the Dodd-Frank Wall Street Reform and Consumer Protection Act’s Title 15 is a “Specialized Corporate Disclosure” provision that you should have seen already: “Section 1502 requires persons to disclose annually whether any conflict minerals that are necessary to the functionality or production of a product of the person, as defined in the provision, originated in the Democratic Republic of the Congo or an adjoining country [...]

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The Policy Supply Chain: Conflict Minerals and Preparing for Mandated Ethical Sourcing

Jason Busch - April 17, 2013 3:01 PM | Categories: Commentary

In the first brief in this research series, Economic and Policy Supply Chain: The “Non-Invisible Hand”, we covered the increasing importance for procurement organizations of looking at economic and policy issues focused on the “Non-Invisible Hand” as we termed it. As we continue our analysis, we will turn our attention to the role not only of specific legislation (such as Dodd-Frank or specifically, Conflict Minerals) on procurement organizations, but also a major policy shift that has already taken place that mandates ethical sourcing compliance. This shift is important. With Conflict Minerals regulations, we have essentially moved into a new era of mandated [...]

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