May 30 Conflict Minerals Filings – Our Initial Review and Thoughts « The Elm Consulting Group International The Elm Consulting Group International. UPDATE: We have standardized benchmarking analyses/reports available for a nominal fee. As of late Sunday night (June 1), we began detailed reviews and summary data collection/analysis on over 100 filing companies representing a range of industry sectors. This will expand over the coming weeks to include the thousands more filings expected by the end of the day today. If you are interested in obtaining a benchmarking report for your company, contact us. We can provide custom reporting as well. Even before we got our first cup of coffee this morning, we went to SEC’s website and perused the recent filings for Form SDs/CMRs. We semi-randomly selected 15 company filings to compare and contrast. Below is summary information of the 15 filings that includes the company name and industry, the link to their SEC filings, excerpts from the documents that we felt we particularly interesting or important, and our comments.
Company: Apple Computers Industry: Electronics, Consumer Goods, Computers. How Intel Audits Conflict Minerals. Gerry Fay - Avoid Conflict: Comply With Dodd-Frank. Conflict-Free Minerals Policy. Conflict Free Minerals Policy Qualcomm is aware that minerals mined in conflict areas in the Democratic Republic of the Congo (DRC) and adjoining countries may be making their way into the electronics industry supply chain and may be fueling human rights violations and environmental degradation in the DRC region. Qualcomm strives to provide DRC conflict free products by supporting industry-wide efforts to drive transparency in the supply chain and by expecting that our suppliers obtain materials from environmentally and socially responsible sources, including conflict free sources within the DRC and adjoining countries.
Background In 2010, the U.S. Congress enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), which required the U.S. Securities and Exchange Commission (SEC) to issue rules requiring certain companies to disclose their use of “conflict minerals”—tantalum, tin, gold or tungsten—that originated in the DRC or adjoining countries.
TPP - Conflict Minerals Reporting Solutions for Dodd Frank Section 1502 | Home > Conflict Minerals Reporting Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act requires all publicly traded companies listed with the Securities and Exchange Commission, irrelevant of the industries that they operate in, to report on the presence and origin of conflict minerals contained within their products. The time and cost associated with contacting suppliers, aggregating data, and properly documenting the presence of conflict minerals in the supply chain can be immense. Our Solution TPP provides clients with data content services and reporting tools to demonstrate due diligence in accordance with Section 1502 of the Dodd-Frank act. Since 2010, TPP has been collecting conflict minerals declarations and EICC/GeSI declarations from suppliers and manufacturers around the world to incorporate into our conflict minerals database.
Users can run reports to: Conflict Minerals Platform: Home. And Conflict-Free Minerals. Global Citizenship: Supply chain responsibility. Annual Report 2012 - Supplier indicators. Philips has a direct business relationship with approximately 10,000 product and component suppliers and 30,000 service providers. Given the size and complexity of our supply chain we need to focus our efforts. Therefore, we developed an approach based on the supplier’s sustainability risk profile related to spend, country of production, business risk and type of supplier relationship. 594 supplier sites have been identified as risk suppliers, including 497 product and component suppliers, and 97 service providers.
Different types of service providers are part of our audit program, including labor agencies and transportation companies. All risk suppliers are by definition part of our audit program. Philips Supplier Sustainability Declaration The Philips Supplier Sustainability Declaration is based on the EICC code of conduct and we added requirements on Freedom of Association and Collective Bargaining. 2012 supplier sustainability audits Number of initial and continual conformance audits. Annual Report 2012 - Conflict minerals: issues further down the chain. Philips is concerned about the situation in the east of the Democratic Republic of the Congo (DRC) where proceeds from the extractives sector are used to finance rebel conflicts in the region.
Philips is committed to address this issue through the means and influencing mechanisms available to us, even though we do not directly source minerals from the DRC and mines are typically seven or more tiers removed from our direct suppliers. During 2012 we worked with 347 priority suppliers to raise awareness and start supply chain investigations to determine the origin of the metals in our products.
This resulted in the identification of 127 smelters in our supply chain that were used to process these metals. We encourage all smelters in our supply chain to participate in the EICC-GeSI Conflict Free Smelter program. We believe that industry collaboration and stakeholder dialogue are important to create impact at deeper levels of our supply chain. News - HP Releases List of Supply Chain Smelters. PALO ALTO, Calif. — HP today published a list of the 195 smelters that have been identified within its supply chain.
HP is the first IT company to publish its supply chain smelter list and to have the smelter identification process be independently reviewed. This move underscores HP’s leadership toward achieving a conflict-free supply chain by encouraging suppliers to become conflict-free smelter (CFS) certified and urging the entire industry to move toward greater utilization of conflict-free smelters and refiners. For more than a decade, the mining of minerals used to produce tantalum, tin, tungsten and gold (3TG) in the Democratic Republic of Congo (DRC) has been linked to the funding of armed groups waging a civil war in the country. These metals are widely used in many industries and are commonly found in electronic products.
“HP has shown leadership throughout the past four years around addressing conflict minerals within its supply chain. About HP.