Conflict Minerals Filings Below Estimates

by | Jun 26, 2014

Conflict mineralsMore than 1,300 companies made their first conflict minerals filings in accordance with a new Securities and Exchange Commission rule, though the number was far less than expected, according to a report by Ernst & Young.

Early estimates indicated around 6,000 companies would be affected by the rule and that 4,500 would be required to file a conflict minerals report with the SEC. Ultimately only 1,315 companies filed a Form SD, and of those, only 77 percent filed an associated CMR.

Many companies indicated earlier this year that they were unlikely to meet the May 31 deadline.

Of the companies that did file, only four obtained an independent private sector audit of their CMR that included the due diligence framework and activities undertaken.

Most filers were not able to determine the origin of tungsten, tantalum, tin and gold in their products and filed a CMR stating the need for further due diligence. In addition, more than 40 percent of filers said that at least some portion of their sourcing originates in the covered countries, but indicated that additional due diligence was needed for some portion of their product components and suppliers.

About half of the filers were able to identify some portion of smelters as conflict-free, but only 27 percent provided a list of smelters and refiners.

Many of the reporting companies have complex supply chains and noted difficulties in tracing the 3TG in their products because of insufficient responses to their inquiries from suppliers. Uncooperative suppliers, as a whole, were reported as the reason why many of the CMRs did not include the level of detail that was expected.

The top 10 sectors with SD filings were:

• 22 percent, technology
• 14 percent, diversified industrial projects
• 13 percent, consumer projects
• 11 percent, retail and wholesale
• 9 percent, pharmaceuticals
• 6 percent, oil and gas
• 5 percent, automotive
• 4 percent, aerospace and defense
• 4 percent, chemicals
• 3 percent, mining and metals
• 9 percent, all other sectors

Photo Credit: Poura Gold Mine, Gilles Paire/

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