Conflict Minerals EDGE: Corporate Policy and Compliance Philosophy

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 free strategy? Will you offer incentives for positive supplier engagement, or will you pursue a more “stick” and less “carrot” driven approach with your supply chain? Will you go down a list of past tier one suppliers in your direct efforts to drive visibility, traceability, and compliance? These are all questions best tackled as early as possible in defining corporate policy.

Philosophy and corporate policy also extend to specific conflict minerals compliance strategies, including whether companies should take a supplier-level or part-level approach to documenting processes and traceability. Lawrence also suggests that in defining corporate philosophy, it can be a good time to get everyone on the same page internally about preparing to “walk the talk.” Will front-line category managers, sourcing managers, and plant managers be willing to terminate supplier relationships with vendors who do not provide enough visibility or attempt to otherwise circumvent requests and efforts?

How you plan for supplier contingencies and create more flexible supply chains looking at conflict minerals compliance is as much about philosophy and policy as it is sourcing and supplier management tactics and execution. Further, Lawrence suggests, get everyone on the same page internally and build alignment around the limits of how far you will go to drive compliance with your supply base – versus issuing edicts and requirements alone.

Stay tuned.

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