Complying with the initial deadline to report on the use of conflict minerals has been a mad scramble for companies that have had to reach out to hundreds, thousands, or even tens of thousands of suppliers to ascertain whether their products contain the minerals in question.
The Securities and Exchange Commission’s (SEC’s) conflict minerals disclosure requirement was mandated by Dodd-Frank and aims to eliminate the use of four minerals—tantalum, tin, tungsten, and gold—when they are providing funding for groups involved in human rights violations in the Democratic Republic of the Congo.
Companies also have to consider what put into their report. Littenberg noted that the conflict minerals rule is principles-based, so companies have discretion over how to put together the report. “This is not a fill-in-the-blank form,” he said. “There’s a lot of judgment that goes into this.”