The Elm Consulting Group International LLC is preparing its Self-Implemented Conflict Minerals Audit Preparation© tool, or SICMAP℠, for a major update reflecting the upcoming final SEC regulations on conflict minerals. In addition, the tool will be renamed/rebranded to better reflect its use and scope. Upon its update and relaunch, it will be called the Conflict Minerals Self Diagnostic© or CMSD℠.
Lawrence Heim, Elm’s conflict minerals service leader:
When SICMAP℠ was developed last year, companies were expressing concerns about the audit element of the conflict minerals regulation. As the issue has evolved and companies have learned more, questions turned to the due diligence process itself. Therefore, we felt that the upcoming regulatory update was an appropriate time to more clearly communicate the tool’s capabilities by changing its name.
CMSD℠ will retain the previous features and functionality, such as:
- “At a glance” color-coding indicating progress/status
- Tabbed sections for each major program element
- Live web links to reference materials
- Summaries of language from the U.S. law and final SEC regulation
- Pragmatic guidance on each element based on actual conflict minerals experience
- Detailed step-by-step direction on conducting “reasonable country of origin inquiry”
CMSD℠ Version 1.0 Table of Contents
I. Initial decisions related to manufacturing, contract manufacturing, use/necessity of conflict minerals and internal ownership of the conflict mineral traceability process
II. Reasonable assurance and representative sampling guidance reflecting SEC audit standards
III. Supplier/vendor risk assessment structure; supplier/product prioritization; use of and reliance on supplier data and other information sources
IV. Information management systems
V. Supply chain mapping considerations
VI. Management system controls, including policies, contract terms, procurement standards and management of change; reporting to management
VII. Communications planning and content; determining customer expectations; external reporting
VIII. Material purchase transaction tracking and source confirmation; material traceability in internal storage, processing, manufacturing and shipping
IX. Audit preparation exercises
X. Auditor selection considerations
The updated release of CMSD℠ will be publicly available within three weeks after promulgation of the final conflict minerals regulation by SEC.
Initially released in summer 2011, the Self-Implemented Conflict Minerals Audit Preparation© tool, or SICMAP℠, was intended to be used by companies in assessing their internal conflict minerals management systems, identifying areas for improvement and preparing for audits of various types. Please contact us for more information or for a demo version.