The Conflict Minerals Rule could be a significant burden for affected companies. To meet the new requirements, companies will need accurate databases containing the necessary information and evidence of compliance from all suppliers. Here are suggestions from Michael Littenberg of the law firm Schulte Roth and Zabel; more information is available at www.srz.com/Conflict_Minerals_Resource_Center.
Create an internal Conflict Minerals Rule compliance team. Members should include representatives from at least manufacturing, engineering, procurement, IT, finance, internal audit and legal departments. Management should empower the project leader with the authority to develop and implement the program and create whatever motivation is necessary to ensure cooperation.
Conduct internal training sessions. Given its complexity, it’s unrealistic to expect people to have a good understanding of the rule based solely on a written summary.
Scope out the project. Determine products that might be implicated, set up a work plan, timeline and budget, and weigh the pros and cons of outsourcing some of the heavy lifting.
Assemble a database of supplier personnel who should receive compliance materials. Develop supplier questionnaires and determine additional documentation requirements.