Highlights of the summary include a simplified explanation of the compliance process. According to the document, a company must determine whether it is subject to conflict minerals requirements. If the answer is yes, the company must conduct a reasonable country of origin inquiry to determine if the “necessary conflict minerals” used originated in the covered countries or are from recycled or scrap materials. Similarly, If a company determines, or has reason to believe, that the conflict minerals originated in the covered countries and are not, or may not be, from recycled scrap sources, it must exercise due diligence on the source and chain of custody of conflict minerals. In some cases, the company may need to provide a conflict minerals report (CMR).
Additional points include information on “phase-in” period implementation, audit standards and objectives, definitions of terms, conflict minerals report content and disclosure requirements.
IPC also plans to publish a due diligence guideline document later this year. “The document is intended to provide industry guidance within a flexible framework that companies may use to establish an effective conflict minerals due diligence program," said Joel Sherman, product environmental compliance manager, Kemet Electronics Corp. "We’re earnestly working to get the guideline out in November." To download “Summary of the Final SEC Rules on Conflict Minerals,” visit www.ipc.org/conflict-minerals-summary.
