Since Section 1502 of the Dodd-Frank Act became law, company internal knowledge of the conflict minerals compliance requirements has evolved, sped along further by SEC’s adoption of their final conflict minerals regulations in August 2012. And in-house expertise has been supported by trade group/industrial association programs and guidance.
Companies already struggling with budgetary constraints reduced their expectations for obtaining outside advisory/consulting assistance. Yet at the same time, many companies are keenly interested in a third party assessment or validation of the work they have done. Without the ability to pay external resources for such a “navigation check”, these companies faced a quandary.
To fill this need, Elm Sustainability Partners LLC developed CMCheckPointSM.
Completely unique in the marketplace, CMCheckPointSM is a detailed conflict minerals program assessment tool for downstream companies. It can be implemented by internal staff to review compliance and implementation decisions and strategies, track completion of program development, build a library of references to key documents/locations and even score severity of identified gaps.
CMCheckPointSM is not an IT system for supplier engagement/response tracking/data exchange, but a spreadsheet for creating/evaluating overarching management programs and regulatory compliance decisions applicable to downstream companies. It covers the SEC regulatory elements, the OECD 5 step framework and related supplements.
“This tool has developed through various forms for longer than most consulting firms have been in the conflict minerals advisory space,” said Lawrence Heim, Managing Director of Elm Sustainability Partners LLC.
Heim continued: “CMCheckPointSM reflects project experience (including Fortune 200 companies) and scores of detailed discussions/reviews with many of the world’s most recognized corporate leaders in conflict minerals program development. It is also the result of hundreds of research hours, sifting through the regulation and preamble; guidance documents from industry associations, law firms, accounting firms, international organizations; comment letters to SEC’s proposed regulation; GAO documents; certain legal filings; and publicly available information from credible sources like the OECD Pilot Program Reports.”
See screenshots (in pop-up windows) below or watch the overview video.
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