| Declaring Conflict-free: Response to the 2010 Dodd-Frank Act Section 1502 (PSX 2019 On Demand) | |
| Dodd-Frank Act section 1502 requires publicly traded companies to annually submit a Form SD to the SEC by May 31 for the proceeding reportable year. On the Form SD, the company may declare themselves 'Conflict-free' with regards to minerals attained from the Democratic Republic of the Congo. These minerals are defined as '3TG' (tin, tungsten, tantalum, gold). Information is collected on Responsible Mineral Initiative (RMI) documentation (conflict Mineral Reporting Template (CMRT)) for the purpose of revealing the sourcing by smelters from the DRC. Those smelters must be Responsible Mineral Assurance Program (RMAP) compliant or are considered HIGH RISK (HR) smelters and prevent the declaration of 'Conflict-free' on the Form SD. After consolidating the CMRT into a Technical File and compiling a Conflict Mineral Report (CMR), an Independent Third Party Audit (ISPA) is performed to assure due diligence per OECD guidelines. Acquiring an assurance by the ISPA auditor that due diligence has been followed to declare 'Conflict-free' on the CMR, then the Form SD can declare 'Conflict-free'. We will focus on how to prepare for the audit and present the information.
Presenter(s): Fred Levko, Director, Product Stewardship, Smith and Nephew, Inc. |
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