Conflict Minerals Compliance & Brand Protection
The conflict minerals rule is an example of a growing regulatory trend toward mandating supply chain transparency and disclosure as a means to other ends. Market pressures often exceed the significance of the rule’s actual compliance requirements. While, for a variety of reasons, businesses need to be working toward improved conflict minerals rule compliance, those with the most strategic outlook are integrating these programs with others attuned to corporate risk and brand protection.
Compliance is a Process, Not an Event
Identify and Assess Risk Areas
- Is the company aware of compliance requirements?
- Have any processes or procedures been put in place?
- Are there immediately identifiable red flags?
Develop or Revise Policies and Procedures
- Assist employer to establish or amend processes and procedures to ensure Conflict Minerals filings are completed correctly and timely.
- Advise on proper storage, retention and destruction policies.
- Establish policies in the event of audit or investigation.
Train and Educate
- Prepare materials and conduct training for management and employees on Conflict Minerals compliance.
- Continually advise on new rules and regulations and ways to protect the company brand.
Monitor and Audit
- Monitor efficacy of, and compliance with, Conflict Minerals policies and procedures.
Revise and Adapt
- Revise policies and procedures to increase efficiencies, correct deficiencies and adapt to changes in Conflict Minerals rules and regulations.
- Advise and defend companies subject to Conflict Minerals audit.
- Negotiate with government agencies to reduce fines and penalties for non-compliance.