Conflict Minerals in the Congo Area“Conflict Minerals” is the term coined by industry to describe the four metals (tin, tungsten, tantalum and gold), that are at the heart of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.  This law requires companies that are publicly listed in United States to report annually to the Securities Exchange Commission (“SEC”) on efforts to identify the country of origin of specific conflict minerals in their supply chain and determine if they came from the Congo (“DRC”) and adjoining countries.   The first report must be filed with the SEC on May 31, 2014 for the 2013 calendar year.The OECD due diligence framework for compliance with this legislation is strikingly similar to the compliance framework mandated by the European RoHS Directive.  It requires a risk-based approach in which companies collect and manage certificates and test reports in the same manner as they do for RoHS.  This uniquely positions Symphony as one of few consulting firms that has a demonstrated track record in this area.

Symphony Consulting’s services in Conflict Minerals include:

  • Conducting a risk-assessment of your components and suppliers, identifying where the four metals of interest are potentially used
  • Designing a due diligence process and establishing a policy
  • Training your suppliers – particularly the smaller companies – and helping them implement programs that support your policy
  • Managing the data received from suppliers, reviewing declarations for accuracy, and reporting compliance percentages per the OECD guidelines