As a result of the Securities and Exchange Commission's (SEC) final rule on Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Final Rule"), private companies not legally subject to the Final Rule's reporting . Some commentators stated that the final rule should not necessarily require private companies to submit to us their conflict minerals information, but the final rule should provide mechanisms that allow private companies to report voluntarily on their conflict minerals in a manner similar to Sections 13(a) and 15(d) issuers, which could include . - What are conflic

Semiconductor vendors, most major consumer electronic OEMs and other high-tech companies largely ignored the voluntary independent audit requirement for compliance with the Dodd-Franks Conflict Minerals legislation in 2013 and this will most likely remain unchanged for 2014, according to a report compiled by Schulte Roth & Zabel, a law firm that provides advisory services to some of the .

In response, the AIAG formed a working group to allow member companies to share resources in identifying conflict minerals throughout the supply chain. The SEC's conflict minerals reporting rules became effective January 1, 2013, and those rules impose burdens on companies throughout the automotive supply chain, given how prevalent the so-called "conflict minerals" are in automotive applications.

Conflict Minerals Compliance & Reporting Requirements Continue to Face Uncertain Future. Source Intelligence Conflict Minerals Compliance Solution.

Private companies are not required to file annual reports under SEC but if their customers are publicly-traded on the US stock exchange and are liable to file conflict minerals report, then the company should also report under SEC on the Origin and mining procedures of the minerals. U.S. Conflict Mineral Contact: If you have any questions, comments or suggestions regarding conflict minerals program for Advanced Semiconductor Engineering Inc., please contact. The Conflict Minerals Compliance Committee provides cross functional expertise for our conflict minerals compliance program.

a description of the measures taken to exercise due diligence on the source and chain of custody of such minerals 2. an independent private sector audit conducted in accordance with standards established by the SEC .

Generally, Conflict Minerals .

. HanesBrands is committed to sourcing materials from companies that share our values regarding human rights, ethics and environmental responsibility. This is the Conflict Minerals Report of Fossil Group, Inc. (references to "Fossil", "we" and "our" refer to Fossil Group, Inc. together with all of its subsidiaries) for calendar year 2021 provided in accordance with Rule 13p-1 ("Rule 13p-1") under the Securities Exchange Act of 1934 (the "1934 Act"). Please refer to Rule . Companies can build on their experiences in conflict minerals compliance, or on those of other companies, to address requirements around human rights and anti-human trafficking.

Neil Mendenhall |. The first conflict minerals reporting period for all public companies will be from Jan. 1, 2013 to Dec. 31, 2013, and the first specialized disclosure report on Form SD must be filed with the SEC on or before May 31, 2014. Item 1.01(b) requires companies that are able to conclude based on this inquiry that their conflict minerals originated outside of the DRC or from recycled or scrap sources to include "Conflict Minerals Disclosure" in their Form SD filings and websites briefly describing the country of origin inquiry and its results. . .

The Conflict Minerals Rule imposes substantial compliance obligations on a significant portion of the public company universe across a wide range of industries. The staff of the SEC has stated in an FAQ that it will not object if a newly public company begins reporting on conflict minerals usage on this same timetable.

independent private sector audit under the conflict minerals rule (for information on the audit requirement, see Practice Note, Conflict Minerals Diligence: Conflict Minerals Audit (0-510-6930)). Our third-party Conflict Minerals Report auditing and . Suppliers can use the iPoint Conflict Minerals Platform [30] [31] to track their compliance and provide mandated quarterly reporting in support of the legislation.

Conflict Minerals Compliance Services.

The Regulation also will impact a large number of companies not directly subject to it, as has been the case with the U.S. Conflict Minerals Compliance Conflict Minerals China RoHS Table Certifications Conflict Mineral Compliance Statement One of the biggest concerns in the technology industry is the fair and ethical use of components sourced from known conflict-affected areas. www.assentcompliance.com Assent Compliance answers the most common frequently asked questions with regards to conflict mineral compliance. The staff of the SEC has stated in an FAQ that it will not object if a newly public company begins reporting on conflict minerals usage on this same timetable. Source: Dorothy Kosich, Mineweb (7/15/13) "The PwC survey determined that the single biggest challenge for companies is getting accurate information from their suppliers." . The starkest, contemporary example of conflict minerals has been the role played by tantalum, tin, tungsten, and gold in the intractable instability of the Great Lakes Region of Central Africa, most notably the eastern part of the Democratic Republic of Congo. Ropes & Gray is a leader in advising companies on global conflict minerals compliance.

The conflict minerals rule applies to all companies that are Exchange Act registrants, including foreign private issuers, emerging growth companies and smaller reporting companies.

We expect to see companies place a strong focus on internal systems and framework development this year, along with a handful of other mainstays including improved supplier engagement and integrating conflict minerals reporting into the broader risk management strategy.

Although the conflict minerals rule technically applies only to public companies, it will have a significant impact on any company anywhere in the world, public or private .

Satisfy due diligence requirements for Dodd-Frank (1502) and the EU Conflict Minerals Regulation (2017/821) and comply with public reporting mandates from the US Securities and Exchange Commission (SEC) and EU regulators with SCS Global Services. 1.Every year, USI undergo IPSA 2 on the results of supplier due diligence and our targeted supplier 3 used 100% only from qualified smelters.. 2.USI as a subsidiary of ASEH, discloses conflict minerals investigation results through ASEH annal Conflict Minerals report filing to the US Security and Exchange Commission.

In January 2014, the American Institute Answer: Companies not subject to the SEC rules disclosures are driven entirely by customer requirements, unless they fall in scope of the EU Conflict Minerals Rules, EU non-financial reporting rules, or various U.S. State government procurement rules. The SEC estimates that approximately 6,000 registrants use conflict minerals and that approximately 1,200 of those companies will need to prepare a Conflict Minerals Report. An Vinh Joint Stock Mineral Processing Company .

Step 1: Responsible Procurement of Minerals. With so much importance being placed on responsible mineral reporting, this should be

Private companies that supply goods to public companies may also be affected. Companies Covered by the Conflict Minerals Rule . Conflict Minerals.

The conflict minerals survey obligations and programs are driven by customer requests; as long . Those experiences apply to activities such as organizational policy development, program governance and execution, training, and auditing and disclosure.

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Wait Not So Fast.

While these four minerals have been identified as playing a distinct role in this .

Schedule automated reminders to send to your suppliers requesting CMRTs, monitor responses, and roll up all information into one concise report.

2. Tags: 3TG, Brexit, conflict minerals, EU COVID-19 and Conflict Minerals.

We are the only law firm member of the Responsible Minerals .

Private companies are voluntarily . Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, and the Securities and Exchange Commission Rules adopted in connection therewith, require certain corporations to report the use of "Conflict Minerals" in the manufacture of their products. Consider creating a conflict minerals compliance .

Parts of this article (those related to the EU (they have passed legislation on conflict minerals)) need to be updated.

The "conflict minerals" provisioncommonly known as Section 1502 of the Dodd Frank Act requires U.S. publicly-listed companies to check their supply chains for tin, tungsten, tantalum and gold, if they might originate in Congo or its neighbours, take steps to address any risks they find .

This new annual reporting requirement - with an initial deadline of May 31, 2014 - could mean either one of the following issues for you: A supply chain issue. For example, if a public company acquires a private company during July 2019, it would not be required to report on the acquired company's conflict minerals usage until calendar 2021.

For most cases a conflict minerals compliance process is .

Companies who use these metals produced in DRC (Democratic Republic of Congo) or elsewhere need to declare it in their annual statement to SEC.

Although the conflict minerals rule technically applies only to public companies, it will have a significant impact on any company anywhere in the world, public or private .

Certified conflict-free smelters are validated as compliant to the EICC (Electronic The SEC estimates that approximately 6,000 registrants are impacted by the rule and that 75 percent of these registrants will be required to file a Conflict Minerals Report thereunder. Standardized reporting process.

ASE_CM@aseglobal.com.

The law also supports the development of local communities. 3TG is a shortened catch-phrase referring to the red-flag minerals of tungsten, tantalum, tin, and gold, which are frequently mined in or around the conflict region of the DRC. All major importers of Tin, Tungsten, Tantalum, and Gold i.e., 3TG; needs to declare the source of import supporting the international efforts to .

In 2010, the U.S. Congress passed a landmark law.

For example, if a public company acquires a private company during July 2019, it would not be required to report on the acquired company's conflict minerals usage until calendar 2021. Also, private companies and companies that are part of the US company's supply chains will be affected, as the requirements are cascaded down the value chain. The rule, which requires companies to investigate and publicly disclose . Although compliance with the rule has proved costly, collecting and evaluating information about conflict minerals helps companies identify opportunities for improving supply chain transparency, practice better risk management, and improve overall operations and compliance ("IPSA Facto: Anticipating the Independent Private Sector Audit after .

On August . Many private companies in the supply chain of registrants find themselves obligated to put in place a conflict minerals compliance program to enable credible and reliable reporting to meet commercial requirements of their customers.

The rules, adopted by the SEC in August, require companies' disclose for calendar year 2013 (regardless of their fiscal .

It may sound like a tedious step forward, but without the right foundation .

The Conflict Minerals Rule imposes substantial compliance obligations on a significant portion of the public company universe across a wide range of industries. EnPro Industries, Inc. and its subsidiaries ("EnPro") are committed to sourcing components and materials from companies that share our values regarding respect for human rights, integrity and environmental responsibility.

In terms of conflict mineral reporting, going from zero to quite a lot can cause operational whiplash.

The Office of Threat Finance Countermeasures, in conjunction with other State Department bureaus and U.S. agencies, actively works to sever the links between mineral resources and conflict through government-to-government diplomatic efforts. Survey: Companies 'Utterly Unprepared' for SEC Conflict Minerals Compliance. . The SEC has prepared a helpful flowchart to guide companies to comply with the conflict minerals rules. 1.

. For manufacturing companies in Kansas City still lacking a strategy, now is the time to act. 2.

A handful of companies also provided independent private-sector audits (IPSAs) as contemplated by the rule. but more effort is necessary for compliance.

acquisitions and dispositions for public and private companies in a wide range of sell-side and buy . Since its adoption by the SEC in September 2012 as part of the implementation of the 2010 Dodd-Frank Act, the Conflict Minerals Rule has faced a series of interesting developments.

With new financial reporting and accounting regulations requiring companies to report the use of minerals mined in certain geographic regions and used within an organization's supply chain, many finance leaders are finding compliance to be complex.

Companies must implement a clear and defined .

We are the only law firm member of the Responsible Minerals . Independent Private Sector Audit and Public Disclosure.

Therefore, the EU passed a new regulation in May 2017 to stop: global and EU smelters and refiners from using conflict minerals, and; mine workers from being abused.

On August 22, 2012, the Securities and Exchange Commission ("SEC") adopted a new rule and form, as mandated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act"), to require companies to publicly disclose their use of conflict . . Sponsored by: Nucor, D&B, and Supply Dynamics, MetalMiner tackles two key "firsts" of conflict minerals compliance including: An overview of specific technology approaches for companies needing to comply with Section 1502 of Dodd-Frank A specific "A-to-Z" guide of semi-finished forms of metal containing conflict minerals and their .

As a result of the Securities and Exchange Commission's (SEC) final rule on Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Final Rule"), private companies not legally subject to the Final Rule's reporting . For most companies, an audit will be required beginning with the 2015 compliance period. Compliance. Division of Corporation Finance Conflict Minerals Disclosure A Small Entity Compliance Guide 1 Introduction.

Conflict Minerals Policy Statement. The first stepbuilding the foundationis to review your products and supply chains for the use of tin, tantalum, gold, and tungsten and determine whether they were mined from the war-torn Congo. Email.

Therefore, fully understanding reporting requirements and their timing, navigating the legislation and ensuring compliance demands private companies' focus.

The Conflict Minerals Rule was adopted during August 2012 and took effect at the beginning of 2013. The first two stages will influence the need for the final step. If products supplied to Ecolab do contain these minerals, the minerals must originate outside the DRC, come from scrap or recycled sources, or be supplied from smelters that have been validated by an independent private sector party to be conflict-free.

The act requires publicly-traded corporations to report the use of "Conflict .

The SEC estimates that approximately 6,000 registrants are impacted by the rule and that 75 percent of these registrants will be required to file a Conflict Minerals Report thereunder.

After the link between 3TGs and armed conflict in the DRC was established, the OECD created a five-step framework for private companies to exercise due diligence on their mineral supply chains.

Specifically, many private companies that are suppliers to registrants are receiving requests from these .

ASEH CM Report 2018.

Active in this space since well before the adoption of the Conflict Minerals Rule, we advise many of the world's leading companies - across all major industries - on compliance in this area.

Conflict Minerals: Set a Compliance Strategy Now. Ensure compliance with evolving conflict mineral regulations.

In addition, suppliers are already .

Automate Your 3TG Compliance.

Most of the conflict minerals compliance efforts have been undertaken by in-house personnel. Responsible mineral sourcing is the practice of procuring raw minerals in a way that respects human rights, protects human and environmental health, combats forced labor, child labor, sexual exploitation of women and girls, human trafficking, and slavery.

We also have a Conflict Minerals Executive Steering Committee composed of executives in Global Purchasing and Supply Chain, Legal, Sustainability, and Public Policy. As companies form cross-functional teams to track the minerals in their supply chains, trade organizations are developing efficiencies that could aid in compliance with the rule, which sets an international precedent for the rigorous way in which it demands tracing of conflict minerals. Conflict Minerals Compliance. Regardless of the path ahead each company chooses, conflict mineral compliance will be on the lips of many executives, compliance officers, and supply chain managers in 2013.

Active in this space since well before the adoption of the Conflict Minerals Rule, we advise many of the world's leading companies - across all major industries - on compliance in this area. 82% We've increased our customer's average supplier response rate to 82%. Importers that are subject to the Regulation will of course need to take the CAHRA list into account in their due diligence. The term "DRC conflict-free" means (1) that a product does not contain any tantalum, tin, tungsten or gold (3TGs) necessary to the functionality or production of that . There are three steps in this compliance procedure.

Axiom Compliance conflict mineral strategy, consulting and auditing services provide guidance to help companies comply with US requirements.

Help our suppliers understand the due diligence steps they can take to investigate the source of any Conflict Minerals in the products they sell to .

The Securities and Exchange Commission's conflict minerals rule could be compared to building a house.

Analogic recognizes the complexity of using these minerals and willingly provides this conflict minerals disclosure statement. A new EU law to stem the trade in conflict minerals.

Regulations surrounding conflict minerals 1 break new ground in requiring end-to-end responsibility throughout the product lifecycle. Conflict Minerals Rule.

A compliance issue. For complete file of ASE Technology Holding SEC Conflict Minerals Filing: ASEH CM Report 2020. 78 We're enabling companies to report up to 78 pages of compliance data. It follows then that a private company that seeks to go public has much to do.

Ropes & Gray is a leader in advising companies on global conflict minerals compliance. +1 510.452.8018 |. Axiom Compliance conflict mineral strategy, consulting and auditing services provide guidance to help companies comply with US requirements.

Companies or entities are required to submit Conflict Minerals Reports to the SEC if: (a) they are required to file reports with the SEC under the Securities and Exchange Act of 1934 and (b) conflict minerals are necessary to the functionality or production of products that they manufacture or contract to be manufactured. ai_phone 877.916.6337 headset_mic Help and Support .

The SEC estimates that approximately 6,000 registrants use conflict minerals and that approximately 1,200 of those companies will need to prepare a Conflict Minerals Report. Following the passage of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act in 2010, conflict mineral reporting has continued to evolve.

Most companies are still building that .

its conflict minerals compliance program to address the requirements of the EU regulation. Conflict Minerals Compliance Statement. Step 1: Responsible Procurement of Minerals.

The office also builds international support for due diligence guidelines intended to help industry develop a responsible minerals trade from conflict .

Companies must implement a clear and defined .

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act passed in July of 2010, is an attempt to prevent rebel groups in the Democratic Republic of the Congo (DRC) from illegally using profits from the minerals trade to fund their activities.

The Conflict Minerals Compliance is intended to support the international efforts to reduce trading in minerals sourced from conflict zones ('conflict minerals').It primarily requires companies that buy products containing Tin, Tungsten, Tantalum or Gold (3TG) to report on the procurement source of these minerals, and this, in turn, affects the entire downward .

Since then, many companies have made significant Those hoping for updated SEC guidance that would relieve or reduce companies' conflict minerals diligence and disclosure obligations for calendar year 2016 got only a fraction of what they wanted.

It is well known that human rights violations have been associated with the mining of certain minerals from the eastern portion of the . Conflict Minerals Requirements: . As an industry leader in compliance, Enventure is one of the first companies to offer services that enable companies to comply with Conflict Minerals regulation. In accordance with Company 's conflict minerals policy, suppliers are expected to supply " DRC conflict- free " materials.

Accordingly, a registrant will need to have its conflict minerals compliance program in place prior to Jan. 1, 2013.

3 CONFLICT MINERAL COMPLIANCE HAT IT MEANS OR PRIVATE COMPANIES THE IMPORTANCE OF CONFLICT MINERAL COMPLIANCE MARKET PRESSURE . The Conflict Minerals Rule imposes substantial compliance obligations on a significant portion of the public company universe across a wide range of industries.

The rule itself included no specific required form of disclosure.

An ethical issue.

On August 22, 2012, the final rule regarding sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("the Dodd-Frank .

And now, with existing requirements under . Gain insights on reporting requirements of the SEC Conflict Mineral Rule.

It requires EU companies to ensure they import these minerals and .

The Regulation will be a game changer for conflict minerals compliance.

Conflict minerals include Tin, Tantalum, Tungsten and Gold popularly known as 3TG. Our customizable, AI-powered platform gathers Conflict Minerals Reporting Templates (CMRTs) from your suppliers regarding the origin of the 3TG used in your products. iPoint Conflict Minerals is a cloud-based software solution that enables companies to address the challenge of collecting, managing, aggregating and reporting on conflict minerals and meeting the requirements of their customers and regulatory authorities. Last Friday, April 7, 2017, the SECs Acting Chair Michael Piwowar issued a statement that said "it is difficult to conceive . A select few electronics companies have energised the initiative to encourage conflict-free mining. (May 2015) The examples and perspective in this article may not represent a worldwide view of the subject. . Private companies that establish robust CSR programs can use that foresight to differentiate themselves from competitors.

Active in this space since well before the adoption of the Conflict Minerals Rule, we advise many of the world's leading companies - across all major industries - on compliance in this area.

These minerals are found in numerous parts used to produce automotive, aerospace, construction, and industrial machinery, medical and dental equipment, and the . - What are conflic Sample 1.

Please help update this article to reflect recent events or newly available information.

Support the aims and objectives of the Dodd-Frank Act concerning Conflict Minerals sourcing by working to educate the manufacturers of the products we distribute about Conflict Minerals.

Conflict Minerals Reporting. Although the conflict mineral rules do not apply to private companies, private companies who supply products to public companies should be aware of the potential impact of the rules on their customers, who may request certifications regarding product sourcing for their own due diligence. The SEC estimates that approximately 6,000 registrants are impacted by the rule and that 75 percent of these registrants will be required to file a Conflict Minerals Report thereunder. Over 1300 companies utilize our Conflict Minerals program.

We are the only law firm member of the Responsible Minerals . Though private companies are often not in scope of the regulation, responsible mineral reporting has nevertheless become an important part of corporate social responsibility (CSR) disclosures. But many companies that use the minerals, notably car and plane makers, have stood back and .

Ropes & Gray is a leader in advising companies on global conflict minerals compliance. ASEH CM Report 2019. These days, the topic of conflict minerals compliance has been the focus of many conversations.

Responsible mineral sourcing is the practice of procuring raw minerals in a way that respects human rights, protects human and environmental health, combats forced labor, child labor, sexual exploitation of women and girls, human trafficking, and slavery. www.assentcompliance.com Assent Compliance answers the most common frequently asked questions with regards to conflict mineral compliance.