New “Expectations” for Conflict Minerals Reporting

The Responsible Sourcing Network (RSN), based on “input from stakeholders across the conflict minerals supply chain,” has published their updated performance criteria for what they consider best practices in conflict minerals reporting to the Securities and Exchange Commission.

Their Indicators Shortlist sets forth 18 performance indicators grouped into four “Measurement Areas”:

  • Assessing Exposure and Responding to Risk
  • Policies and Management Systems
  • Transparency and Reporting
  • Promoting a Conflict-Free Minerals Trade.

The document also addresses RSN’s expectations for Form SDs from issuers who do not conduct due diligence (and therefore do not need to file a Conflict Minerals Report because, based on the Reasonable Country of Origin Inquiry results, the company has no reason to believe it has any material from Covered Countries in its supply chain).  RSN’s description of the desired Form SD content is essentially a mini-CMR.  We remind readers that there will be more scrutiny of Form SD-only filers, so we suggest adequate preparations be made.

RSN further indicated that these indicators were used in a pilot study conducted in partnership with ESG research and analysis firm Sustainalytics.

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