RY2024 Underway!
Reporting Year 2024 (RY2024) is underway marking year 12 of reporting supply chain due diligence of the source and chain of custody of Conflict Minerals under Dodd-Frank. While past events threatened the domestic Conflict Minerals law, there has been no change in reporting under the law.
Conflict Minerals reporting is an annual obligation for companies in scope of the law, and once the requisite forms are filed with the SEC at the end of May each year, efforts begin for the next reporting year if the project is managed appropriately. Although political decisions could impact Conflict Minerals reporting, the RY2024 cycle started as early as June 2024 for companies that continue their due diligence activities. Companies that have been through the disclosure process know that the due diligence process should not be interrupted if filings are to be done appropriately and by the legal deadline.
For more on US Conflict Minerals reporting, continue reading below.
Performing supplier Reasonable Country of Origin Inquiries (RCOIs) and smelter RCOIs, and performing subsequent due diligence on smelters regarding their Conflict Free status, is a daunting task. Copious amounts of errors in supplier Conflict Minerals Reporting Templates (CMRTs) makes cleansing these CMRTs and identifying valid smelters a laborious task. The required research regarding smelters in the DRC and surrounding countries, and performing due diligence on these smelters can also be challenging.
If your company, whether an issuer or an upstream supplier, is still struggling with managing supply chain transparency issues, like Dodd-Frank, let us know how GCG can help. Our successful implementation and management of Conflict Minerals since 2013, for both issuers and suppliers alike, can help you manage your suppliers, conduct supplier and smelter RCOIs, perform required due diligence steps, and prepare form SD and the CMR for the SEC.
Email us at This email address is being protected from spambots. You need JavaScript enabled to view it. or call us at 888.422.4246. General background information about Dodd-Frank is below.
What it is: The Dodd-Frank Wall Street Reform and Consumer Protection Act, signed in to law on July 21, 2010, contains Section 1502 which refers to the use of Conflict Minerals in the Democratic Republic of the Congo (DRC). This section is referred to as the Conflict Minerals Law.
Why it is important: Section 1502 is important to manufacturers and suppliers of electronics because it applies to minerals that are commonly used in electronics.
What you need to know: The Conflict Minerals Law is not a ban on using certain minerals, however it contains reporting and disclosure requirements for materials contained in products, as well as due diligence, audit and certification requirements.
The SEC Fact Sheet for disclosing the use of conflict minerals may be found here: https://www.sec.gov/newsroom/press-releases/2012-2012-163-related-materials
The Final Rule may be found here: https://www.sec.gov/files/rules/final/2012/34-67716.pdf
The SEC Compliance Guide may be found here: https://www.sec.gov/info/smallbus/secg/conflict-minerals-disclosure-small-entity-compliance-guide.htm