To the surprise of many, Apple published its SEC conflict minerals filings today, including the Conflict Minerals Report. Given that the regulatory filing deadline is May 31, the company is 3.5 months ahead.
In our comments about Apple’s CY2013 filing, we felt that the range of actions directly taken and supported by the company were inadequately reflected in the filing, giving readers the impression that Apple took a less active role in addressing conflict minerals than they actually did. In contrast, the CY2014 CMR is much more explicit and clear about what the company did both directly and related to supplier mandates.
In many ways, this CMR silences the accusations made in the recent Newsweek article. In our opinion, the frankness of this current CMR negates Newsweek’s claim that Apple has misrepresented facts about their situation. Although we feel that parts of Newsweek’s article were generally correct, other aspects were misinformed. For instance, in their interview with us for the same article, the reporter was totally unaware that Apple and Intel employees had made numerous smelter and mine visits around the globe, and used that first hand information in many instances to support their reliance on the CFSI smelter audit program.
Finally, Apple’s CMR will likely be the model others follow in drafting their own CMRs for the May 31 deadline.