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Conflict minerals

Compliance considerations for private companies

As a result of the Securities and Exchange Commission’s (SEC) final rule on Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Final Rule”), private companies not legally subject to the Final Rule’s reporting requirements are still impacted. Many private companies in the supply chain of registrants find themselves obligated to put in place a conflict minerals compliance program to enable credible and reliable reporting to meet commercial requirements of their customers. Specifically, many private companies that are suppliers to registrants are receiving requests from these customers to investigate their supply chain and provide information regarding the use of conflict minerals in the products they sell.

What does this mean for private companies?
Bottom line – doing nothing may not be an option. As registrants subject to the Final Rule continue to gain greater insight and visibility into their supply chain procurement practices, they will increase their ability to take actions against non-compliant suppliers. Suppliers that do not comply with registrant customer information requests and other forms of engagement may find themselves at risk of being replaced by other suppliers. Impacted registrants will increasingly be held accountable for the performance of their conflict minerals compliance program performance and thus will increase the pressure on their suppliers to do the same.

Featured insights

Conflict minerals: Compliance considerations for private companies
Publication: 5-page PDF

Conflict minerals: Evolving compliance
Publication: 12-page PDF

Industry insight

Conflict minerals: The retail perspective
Publication: 8-page PDF

Reporting trends

Heads up — Navigating next steps after the year 1 Form SD and conflict minerals reporting cycle
Publication, 12-page PDF

Conflict minerals — Consumer and industrial products
Industry insight, 2-page PDF

Conflict minerals — Energy and resources
Industry insight, 2-page PDF

Conflict minerals — Life sciences and health care
Industry insight, 2-page PDF

Conflict minerals — Technology, media and telecommunications
Industry insight, 2-page PDF

The documents listed below have not yet been updated to reflect the SEC’s May 2, 2014, stay of those portions of its conflict minerals rule that were found to be unconstitutional by the U.S. Court of Appeals for the District of Columbia Circuit on April 14, 2014. Under the ruling and the SEC stay, issuers are still required to file Form SD and, if applicable, a Conflict Minerals Report on or before the June 2, 2014, due date; but they are not required to identify any products as having "not been found to be DRC conflict free" or as "DRC conflict undeterminable." For additional information, see Deloitte’s May 16, 2014, Accounting Journal Entry.

Attachments

Heads Up — Navigating reporting requirements for form SD and conflict minerals reports
Publication, 16-page PDF

Heads Up — As good as gold? SEC issues final rule on conflict minerals
Publication, 12-page PDF

Conflict minerals — IPSA Considerations
Report, 2-page PDF

Conflict minerals — Frequently asked questions
Brochure, 28-page PDF

Conflict minerals — An overview of scope of services including IPSA for audit clients
Brochure, 4-page PDF

Conflict minerals — Services
Brochure, 2-page PDF

Conflict minerals — Aerospace and defense
Brochure, 9-page PDF

Conflict minerals — Automotive
Brochure, 9-page PDF

Conflict minerals — Oil and gas
Brochure, 9-page PDF

Conflict minerals — Process and industrial products
Brochure, 9-page PDF

Conflict minerals — Retail
Brochure, 9-page PDF

Conflict minerals — Technology, media and telecommunications
Brochure, 9-page PDF

As used in this document, "Deloitte" means Deloitte LLP and its subsidiaries. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

Advisory services team

  • Kristen Sullivan
    Partner
    ksullivan@deloitte.com
  • Donald Fields
    Director
    dfields@deloitte.com
  • Jeff Torstenson
    Director
    jtorstenson@deloitte.com

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