Spend Matters » Conflict Minerals

Conflict Minerals Questions Answered

Sheena Moore — Fri, 10 May 2013 19:25:27 +0000

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:

Conflict Minerals Analysis: Readiness, Technology and Questionable Practices

Jason Busch — Wed, 08 May 2013 20:55:37 +0000

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 [...]

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

Jason Busch — Tue, 07 May 2013 21:08:08 +0000

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 [...]

Conflict Minerals EDGE: Compliance Technology (Part 3)

Jason Busch — Tue, 07 May 2013 16:03:54 +0000

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. [...]

Conflict Minerals EDGE: Compliance Technology (Part 2)

Jason Busch — Tue, 07 May 2013 14:06:18 +0000

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 [...]

Conflict Minerals EDGE: Compliance Technology (Part 1)

Jason Busch — Mon, 06 May 2013 20:28:46 +0000

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 [...]

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

Sheena Moore — Mon, 06 May 2013 19:00:20 +0000

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)

Conflict Minerals EDGE: Compliance and Auditing Strategy

Jason Busch — Mon, 06 May 2013 16:01:19 +0000

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 [...]

Conflict Minerals EDGE: Corporate Policy and Compliance Philosophy

Jason Busch — Mon, 06 May 2013 15:25:17 +0000

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 [...]

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

Jason Busch — Mon, 06 May 2013 14:44:30 +0000

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 [...]