The Conflict Free Sourcing Initiative (CFSI) has recently released a 2015 white paper of “Five Practical Steps to Support SEC Conflict Minerals Disclosure.” The best practices guide is more specifically targeted towards “Downstream Companies.” While the complexity of tracing conflict minerals can pose many challenges for companies trying to increase visibility in their supply chain, issuers and non-issuers can gain a better understanding of their requested reporting through best practices guidelines such as CFSI’s white paper.
The “Five Practical Steps to support SEC Conflict Minerals Disclosure” intends to help Downstream Companies identify conflict minerals sourcing in their supply chain, and to help in “making conflict-free sourcing more efficient,” and “to interpret the OECD process in a form that is relevant to Downstream Companies several tiers removed from the SOR.” (Five Practical Steps to Support SEC Conflict Minerals Disclosure White Paper)
A recent article released by JD Supra, “Blog: CFSI posts ‘Five Practical Steps to Support SEC Conflict Minerals Disclosure,’” compares the 2015 and 2013 white papers published by CFSI, and summarizes the 2015 White Paper’s 5 steps of: “Build a Company Conflict Minerals Program Framework,” “Explore Risks in the Supply Chain,” “Develop a Risk Management Plan,” “Audit Smelter or Refiners,” and “Report Findings.”
With regard to step 4, understanding and assessing smelter verification is essential for the success of any conflict minerals program. Consolidating and matching known smelters and assessing conflict-free certification status, are just a few of the challenges that companies are faced with during their due diligence processes.
If you are interested in reading the CFSI white paper more in-depth, refer to this link