Tag Archives: tantalite

Video Introduction to Conflict Minerals tool SICMAP℠ Released

UPDATE:  The tool has been substantially updated, renamed CMCheckPoint℠ and is available from Elm Sustainability Partners, with a new video here.

As previously announced, The Elm Consulting Group International LLC today released its Self-Implemented Conflict Minerals Audit Preparation© (SICMAP℠) for commercial availability. As part of the product release, a short introductory video provides an overview of the tool, its features and functionality.

We are in the process of uploading a true HD version of the video on our website. Until that is completed, the version posted here has limited resolution even when viewed in HD mode (the “HD” icon in the upper right hand corner of the viewer window below.)

If you have access to YouTube, the video can be viewed in better quality here.

Elm Launches Groundbreaking Low Cost Conflict Minerals Audit Preparation Tool

Updated March 2012:  See our most recent announcement.

The Elm Consulting Group International LLC today announces a groundbreaking cost effective tool to support companies preparing for conflict minerals traceability audits or customer inquiries.

The delay in SEC’s final rule triggered many questions from companies about planning and pre-audit preparation.  This led us to a solution that is valuable in almost any foreseeable final regulation scope/content and companies planning responses to customer inquiries – yet significantly reduces costs during this period of uncertainty.

Elm’s Self-Implemented Conflict Minerals Audit Preparation© (SICMAP℠) is conceptually similar to a self-audit checklist.  SICMAP℠ is a spreadsheet tool that maximizes the use of internal company staff for cost reduction and implementation flexibility to develop and review conflict minerals programs in advance of third party auditing.

SICMAP℠ focuses on basic program elements equally relevant to companies responding to customer inquiries/procurement requirements and those working to comply with the upcoming SEC regulations on conflict minerals.   Successive and more complex tasks – for both program development and audit preparation – are identified based on initial SICMAP℠ findings, lessons learned from working through the SICMAP℠ process, and the final regulatory requirements once they are known.  The final rule, when published, will clarify the level of detail for some of the efforts.

Screenshots (which can be enlarged by clicking on them) show some of the features and functionality in SICMAP℠ include:

  • “At a glance” color-coding indicates progress/status of both program development and audit preparation
  • Live links to reference materials on the internet
  • Summaries of language from the U.S. legislation (which will not be changed by SEC’s final regulations)
  • Step-by-step pragmatic guidance on specific program elements
  • Highlights of emerging international initiatives in comparison/contrast to SEC audit standards
Sample Page Showing Detailed Guidance

Topics covered in an intuitive and pragmatic way include:

  • Initial scoping
  • Reasonable assurance and representative sampling concepts reflecting SEC auditor standards
  • Information management systems
  • Internal controls
  • Supply chain mapping
  • Communications planning and content
  • Scrap materials – special definitions and challenges in traceability efforts
  • Considerations in selecting an auditor and preparing for the site visit
Summary Tracking Page With Color Coding. This image shows covered topic tabs along the bottom.

The tool is based on Elm’s experience as one of four firms worldwide that have completed conflict minerals traceability independent audits. Elm’s tantalum traceability audits in 2010 resulted in the first ever “Conflict-Free Smelter” designation*, covering sites in the US and Japan.

We continue to recommend that companies move forward with planning activities, but defer third party audits until planning is substantially complete and the SEC regulations are final.  As with almost any new management program, a formal third party audit should be the last step of the implementation process – not the first.

SICMAP℠ will be commercially available beginning June 6, but feel free to contact us beforehand with questions.

* Issued by the industry association sponsoring the audits.  The Conflict Free Smelter (CFS) program is emerging as the leading conflict minerals third party certification program for smelters by the electronics industry.

Elm to Make Major Conflict Minerals Service Announcement May 31

On Tuesday May 31, The Elm Consulting Group International LLC will formally announce a major development in our conflict minerals traceability services.

Lawrence Heim, Elm Director and leader of the firm’s conflict minerals services:

SEC’s delay in promulgating their final conflict minerals rule has resulted in a significant amount of uncertainty within affected companies.  Many of these companies are challenged by cost constraints as they seek information, guidance and solutions to yet-unknown compliance standards.  Our announcement next week provides a highly cost-effective solution in balancing these challenges.

If you would like to receive the announcement and related information directly, send an email to Lheim@elmgroup.com.

NEWS FLASH: SEC Delays Finalization of Conflict Minerals Regulations Until Second Half 2011

A little more that a week ago, Elm received information from two independent sources that SEC was not going to publish the final Conflict Minerals regulations by the statutory deadline of April 15, 2011.

Today, this was confirmed by information on SEC’s website.  At this time, SEC’s anticipated date range for the final rules is August to December 2011.

Although the delay extends the uncertainty of specifically what the requirements will entail, it provides impacted companies a much-needed expanded window of opportunity to plan basic program elements and begin specific communications with suppliers and customers.

One key element of compliance that won’t change is the complexity of structuring a supply chain-oriented audit program. We have written on this matter several times in the past and continue to counsel clients to begin this planning as soon as possible, and defer any auditing until this has been carefully considered.  Some of our earlier comments on the risks of moving forward in the absence of planning are perhaps even more relevant given the rule’s delay:

  • Companies directly regulated by SEC. Audits conducted “pre-rule” risk being non-compliant with the final SEC requirements.  Early adopters may be faced with paying for audits a second time to achieve compliance.  Reputational damage is possible where companies publicize or market the results of audits that are non-conforming to the final rule.  At an extreme, companies could face lawsuits over nonconforming audits in a manner similar to lawsuits filed for non-GAAP financial reporting or certain corporate social responsibility reports.
  • Privately-held companies responding to customer demands. For these companies, the risk is not compliance oriented, but centers on unnecessary costs and reputational damage.  Where customers demand this information of suppliers, the demands must be met.  The question becomes “is SEC compliance driving the customer’s request?”  If so, …the customer’s need may not be so urgent or burdensome as originally thought; and early adopter efforts on the supplier’s part may be overkill/overly expensive in light of a rule deferral period.  Legal action from customers who rely on the “pre-rule” audit information and reputational damage are both possible where companies publicize or market the results of audits that are non-conforming to the final rule.  Suppliers would be wise to work with customers to find an acceptable balance between the drivers, timing, scope and cost.

… Elm continues to recommend that companies move forward with implementation evaluation, scoping and planning activities, but wait for SEC’s rule to be finalized before conducting audits.

The Commission’s plans for regulatory development of all Dodd-Frank related rules are published in the section of the website titled Implementing Dodd-Frank Wall Street Reform and Consumer Protection Act — Upcoming Activity.

The conflict minerals regulations are listed under the heading Corporate Governance & Disclosure, with the subheading of Section 1502.

In a related matter, many reports during the past week stated that the conflict minerals rules were finalized or went into effect on April 1.  Those reports erroneously used the words “rules” and “regulations” when referring to the voluntary auditing program created by EICC, who announced April 1 as the official commencement date for full program rollout.