Conflict Minerals? We’ll Get Around To It…

A new study released by PwC illustrates a rather stunning trend – most companies still have made little progress toward conflict minerals compliance, and have no idea about the impact the regulations are to have. The survey was conducted in spring 2013 and included 900 individual respondents.

Of the major findings, perhaps this one is most revealing:

If the conclusion is that minerals are NOT conflict free, 28% of respondents don’t expect much business impact, and 40% don’t know or feel it isn’t applicable.

The report itself presents the information in a concise manner, but some of the other major findings are:

  • 26% of the respondents did not know if the rule was even applicable to their companies.
  • 58% of respondents see this only as a compliance exercise and don’t anticipate additional value from the required efforts.
  • 26% of respondents have not established a conflict minerals policy or feel it isn’t applicable.
  • For those that have gathered some data on their suppliers, 54% of the respondents could not determine if minerals originated from covered countries or not.
  • Almost 27% of respondents plan on relying solely on due diligence information received from suppliers; 58% don’t know if they will extend their efforts beyond their Tier 1 suppliers.
  • For data management, 76% of respondents have not determined if they will implement a conflict minerals specific IT solution; almost 9% plan on using an existing system for their conflict minerals data.
  • 44% of respondents expect to file a Form SD, but only 8% expect to also file a Conflict Minerals Report, or CMR (required where a company knows, or has reason to believe, that minerals originated from the Covered Countries).
  • 9% of respondents expect that their CMR will be audited in 2013 (we are not sure why this number is greater than the number of respondents who think they will issue a CMR to begin with); 26% of respondents expect to defer the audit because they anticipate being classified as “undeterminable” for 2013.

Other interesting points from the survey:

  • 25% of respondents appear not to have developed their internal team and don’t know how needs to be involved.
  • 34% of respondents don’t know how many direct suppliers are in their supply chain; 23% have between 100 – 1000 and 17% have less than 100.


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