Conflict Minerals Compliance Training & Guidance
In 2010 President Obama signed the Dodd-Frank Consumer Protection Act into law. Section 1502 of that law requires public companies to report to the Securities and Exchanges Commission the results of due diligence on the supply chains of their products that contain Conflict Minerals. As a result companies are reaching out to their suppliers to gather this required information.
Below are links to information from the US government on both Dodd-Frank
and the Securities and Exchange Commission’s final rule covering conflict minerals.
The Quality Control (QC) process, also known as clarification requests, provides suppliers the opportunity to respond to QC Flags that are raised during the analysis of each submitted CMRT (Conflict Minerals Reporting Template) or declaration. Each declaration submitted into the platform is analyzed for missing or incomplete data, and based on the analysis, may require feedback from the supplier.
QC (Quality Control) FAQs
Why am I being contacted?
You may be receiving this email because your contact information was provided on the declaration submitted.
When am I complete?
Once a supplier has submitted feedback for a declaration, the requestor will be notified and see the response move from the category of “Following Up” category to “Complete” on the platform dashboard.
What about multiple declarations?
If multiple responses (declarations) have been submitted, for example to different requestors, feedback may be required even if the declarations are the same.
What do I do with updates or old information?
Based on the QC Flags raised, you may want to submit a new declaration to your customer/requestor. You may do so by following the same process used to submit your original response. If you feel that a response is no longer relevant to your customer, you may request that it is “archived.” You can archive a response yourself on the platform. Click the ‘Profile’ and then ‘Conflict Minerals’ section. Locate the declaration and click ‘Archive.’ WARNING This will make the declaration inactive and can’t be undone.
How often do I get reminded?
You will be sent three electronic reminders to provide feedback to your customers; after the third reminder the feedback for all QC Flags raised will be set to the default response of “I will not take any further action at this time” and submitted to your customer on your behalf.
How do I access this feedback?
In order to provide your QC feedback, you will first need to log into your Source Intelligence account. This can be accessed at www.sourceintelligence.net; your email address will typically be your username. If you have forgotten your password please use the “Forgot Your Password” link on the log in page.