Conflict minerals reporting challenges U.S. companies and their suppliers

The high cost and uncertainty about requirements have slowed compliance with regulations meant to discourage sales of key minerals to benefit armed groups.

16 July 2015

In 2010, the United States Congress passed the Dodd-Frank Act, mandating the issuance of rules requiring certain companies to disclose their use of conflict minerals if those minerals are "necessary to the functionality or production of a product" manufactured by those companies. Those minerals include tantalum, tin, tungsten or gold (3TG). Congress enacted Section 1502 of the Act because of concerns that the exploitation and trade of conflict minerals by armed groups is helping to finance conflict in the Democratic Republic of Congo region and is contributing to an emergency humanitarian crisis.

Douglas Hileman has over 35 years of experience in compliance, risk management, and auditing, with nine years of experience in industry. He led two Independent Private Sector Audits (IPSAs), one each for the 2013 and 2014 reporting years. His firm (Douglas Hileman Consulting, LLC, in Los Angeles) is one of only six (three based in the U.S.) who have conducted an IPSA submitted to the SEC in the first two reporting years. He helps clients with strategies, compliance (and compliance readiness), program improvements, performance metrics, business processes, transactional support, training, and several types of auditing. He has been involved with Dodd-Frank conflict minerals (DFCM) since submitting comments on the proposed SEC rule. He has helped clients in several aspects of DFCM compliance preparedness, and has published numerous articles for the business community. He launched as a resource for filers and their suppliers.

Dynda Thomas is a partner at Squire Patton Boggs law firm. As founder and leader of the company's conflict minerals team, she focuses on relevant industries' best practices in working with clients' legal, procurement and compliance groups, advising them on the development and improvement of processes and procedures, the interpretation of the US conflict minerals rule and other supply chain regulations globally, and preparation of disclosure and reporting. Thomas advises on developing and reviewing procurement policies, training executives and relevant client teams, planning communications with customers and suppliers, and proposing data gathering and retention policies. She and her team work with companies in a wide variety of industries, including aerospace, automotive, consumer products, electronics and mining. Thomas currently serves as the Chair-Elect of the ABA's Public Utility, Communications, and Transportation Law Section. She is a graduate of the University of Cincinnati College of Law, where she was an Urban Morgan Human Rights Fellow. She holds a bachelor's degree in Diplomacy and Foreign Affairs from Miami University.

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