Conflict Minerals

History and Expertise

We began working with conflict minerals soon after passage of the Dodd-Frank Act in the summer of 2010.  Elm was selected by the Electronics Industry Citizenship Coalition (EICC) as one of the original three firms approved to conduct Conflict-Free Smelter (CFS) audits.   Our audits resulted in the inaugural certifications issued under the program.

Looking forward at that time, we thought there could be perceived conflict of interest in engagements where clients relied on our potential future CFS work.  Therefore, we voluntarily withdrew from our EICC relationship in order to serve clients without concern about such potential impairments.

In addition to our client project work, highlights of our conflict minerals activities include:

  • Being selected as the only environmental/sustainability consultancy selected by the US Securities and Exchange Commission (SEC) as a panelist at their 2011 Conflict Minerals Roundtable.
  • Functioning as the technical subject matter expert on Section 1502, the SEC conflict minerals disclosure requirements and auditing practices in the USAID-funded Capacity Building for Responsible Minerals Trade (CBRMT) to establish the ICGLR Independent Minerals Chain Auditor (IMCA).
  • Providing technical support to the US Department of State Office of Central African Affairs and professional environmental, health, safety and sustainability auditor organizations on conflict minerals audit processes/standards.
  • Leading training/educational offerings sponsored by the American Bar Association, The Society of Corporate Secretaries and Governance Professionals, IPC (a leading electronics industry association), ITRI (the world’s largest tin industry association), EICC/Conflict Free Sourcing Initiative, ThomsonReuters, and Bloomberg BNA among others.
  • Being appointed by The Auditing Roundtable to lead their newly established Interest Group in developing auditor guidance for use by environmental, health, safety and sustainability audit professionals in applying SEC’s Performance Audit standard in conducting independent private sector audits (IPSAs) of CMRs.

Elm is also a founding member of The Conflict Minerals Consortium, the first global cross-industry group to provide a suite of solutions that enable companies across industries to meet the diverse requirements of needs in conflict minerals programs, traceability/due diligence, legal advisory and IT systems.

What We Offer

Elm Sustainability Partners LLC offers cost-effective consulting support, advisory and audit services for conflict minerals.  Examples include:

  • Strategy and regulatory compliance assessments based on our unique CMCheckPointSM tool
  • SEC report development and review
  • Program and procedure development, including
    • ​Product, supplier and material screening
    • Prioritization criteria
    • Reasonable Country of Origin Inquiry (RCOI) processes
    • Due Diligence processes
  • Conflict minerals process workflow mapping/overlays with corporate enterprise-wide systems, such as Oracle’s Agile
  • Ongoing third-party advisory support, oversight and document reviews
  • Training program delivery and material development
  • Conflict Minerals Report IPSAs and preparation/planning.

Email or call us at 678-200-5220 to discuss your unique needs.

Conflict minerals and sustainability advisory and auditing