Tag Archives: conflict metals

New Guide Published on Conflict Minerals

MetalMiner.com, one of the world’s foremost on-line publications on global procurement of metals and related products, including global pricing trends, capacity constraints, supply market M&A activity, today published its guide to planning compliance with the US Conflict Mineral Law and the (soon to be final) implementing regulations under the Securities and Exchange Commission (SEC).

This guide, titled What Your Company Should Know About Conflict Minerals, is a concise resource containing:

  • Elm’s insights from having conducted audits under a leading industry association program for conflict minerals supply chain traceability, and
  • MetalMiner’s expertise in metals trading/sourcing, with a unique perspective on how the scrap loophole may become exploited by operations in the conflict region.

The date is looming for SEC promulgation of the final regulation and over 160 comment letters were submitted to SEC on the proposal.  To help you prepare for these new program requirements, this report provides valuable substantive information based on first hand knowledge of conflict minerals programs and issues.

MetalMiner.com was founded more than four years ago and since then has become a recognized leader in providing unique insight, analysis, and tools for buyers, purchasing professionals, and everyone else for whom metals and their related markets matter.

Click here to obtain a copy of this report from MetalMiner.

Elm Concludes Conflict Minerals Auditing Presentation in San Diego

This week we concluded our presentation giving an overview of Conflict Minerals Traceability auditing under US Securities and Exchange Commission (SEC) regulations on “Conflict Minerals” originating from the Democratic Republic of Congo (DRC).  Lawrence Heim, Director at ELM, presented on Elm’s experiences as part of a panel on sustainability at The Auditing Roundtable Winter Meeting January 25.

The key points made were:

  • Planning is critical.  Because the legal requirements apply to the supply chain rather than a single site, a successful auditing program needs to start as close to the mine as practical then move forward toward the consumer.  Working backwards creates complexities, confusion and increases costs.
  • SEC sees different audit types, but the market doesn’t. SEC’s proposed regulations establish two traceability activities: “reviews” (a less formal, internally-driven screening process) and “Conflict Minerals Reports” (requiring formal third party audits).  However, buyers of affected products/materials are already demanding third party credibility and independence for any material origin statements.  These buyers are increasingly unwilling to rely on statements or declarations of “DRC free” based on the “reviews”.
  • Audits are SEC-based, not EHS. As stated in SEC’s proposal, AICPA-based attestations are a critical component of viable traceability programs.  Requirements for auditor independence, attestation engagements and “audits of the auditors” far exceed similar elements found in traditional EHS auditor standards, certifications and practices.
  • Additional sources of audit information are necessary. Increased stakeholder and regulator concern over information veracity reflecting ore provenance is driving the need for new data resources and verification tools well beyond information available/provided by the audited site.

Heim concludes, “Media coverage has painted an unnecessarily pessimistic picture of the practicality and cost of these conflict minerals audits.  Our experience demonstrates that such pessimism is generally unwarranted, provided the right plan and resources are in place.”

Leading Edge Information Technology to Support Elm’s Conflict Minerals Traceability Services

The Elm Consulting Group International LLC (Elm) earlier this week launched our Conflict Minerals Traceability Service in response to recent US legal and international economic policy developments concerning “Conflict Minerals”.  Conflict Minerals are defined by the United States’ Securities and Exchange Commission (SEC) and the international Organization for Economic Cooperation and Development (OECD) as tin, tantalum, tungsten, gold and the ores from which these materials originate.

Today, Elm announces an enhancement to the Conflict Minerals Traceability Service.  We will be leveraging cutting-edge information technology through our relationship with Sentiment360, a leading Internet data monitoring and analytics company.  Using Sentiment360, Elm’s unparalleled depth of information review – far beyond standard data reviews – may yield critical insight into conflict mineral provenance.

Lawrence Heim, Director at Elm: “As audit activities get closer to the mining and exportation of the ore, concern increases over the veracity of the information.  These concerns have been expressed by the SEC, OECD and by trade associations developing conflict minerals traceability programs.  The public and nongovernmental organizations (NGOs) also have similar apprehensions.”

“In discussions with Sentiment360 soon after Elm broadcast information about our Conflict Minerals Traceability Service, we concluded there is an excellent fit for Sentiment360 in these audits,” Heim continued.

Scott Marticke, Chief Operating Officer for Sentiment360:  “Lawrence reviewed with us the audit frameworks and associated information needs for these complex audits.  It became clear that Sentiment360’s proven real-time data mining and analysis technology addresses specific concerns from many stakeholders on data quality/validity related to mineral sources.  We are excited to be working with Elm on this global issue.”

Sentiment360 is based in Atlanta and provides real time analysis of information trends across global Internet social networks, forums, Blogs, news, video and image sites.   They have been engaged by Fortune 500 companies and US governmental agencies to scour online and internal documents and monitor/analyze online conversations.  Contact Scott Marticke, COO, at (404) 920-4687, or visit us on the web at www.sentiment360.com.

Now Available – Summary Review/Comparison of Conflict Mineral Supply Chain Traceability Audit Programs

Elm has developed a short summary review of conflict minerals audit programs based on our industry-leading first-hand experience conducting these audits, and leveraging our extensive international senior-level health, safety and environmental (HSE) auditing expertise.

If you are interested in receiving our summary document, please send us an email (lheim@elmgroup.com) or feel free to call us.  We look forward to hearing from you soon.


Elm’s Auditing Expertise Extends to “Conflict Mineral” Supply Chain Traceability

The US Securities and Exchange Commission (SEC) gave 2010 an interesting send-off by publishing its proposed regulations on Conflict Minerals Reporting and supply chain traceability on December 15, 2010.  The requirements will impact many industries and companies (U.S. and foreign) in various ways.  The Law itself, the proposed regulations and the Organization for Economic Cooperation and Development (OECD) Conflict Minerals Due Diligence framework create expectations and ambiguities concerning supply chain traceability/auditing programs.

Between August and December, The Elm Consulting Group International, LLC completed one of the first third-party audit/traceability engagements in response to The Conflict Minerals Law and OECD program.  The audits resulted in the first “Conflict-Free Smelter” designation in the United States under the audit program for tantalum.

As a result of that success, we are launching a broadened Conflict Minerals Traceability Auditing service to include tin, tungsten and gold.

To assist clients and others, Elm has developed a short summary review of conflict minerals audit programs – based on our industry-leading first-hand experience conducting these audits, and leveraging our extensive international senior-level health, safety and environmental (HSE) auditing expertise.

If you are interested in receiving our summary document, please contact us.


Founded in 2001, The Elm Consulting Group International, LLC is a specialty health, safety, environmental and sustainability management services firm with 5 offices in the United States, as well as offices in Mexico, Argentina, New Zealand, Indonesia, an exclusive joint venture in China and a network of over 100 hand-selected affiliates in 22 other countries.  To maintain our independence as auditors, our services are focused on audit program development and execution, and we maintain various third-party HSE auditor certifications in the US and abroad.