EICC-GeSI released the latest version of its Conflict Minerals data collection template in April 2014.
Companies listed on the U.S. stock exchange had one year since the final rule update in May 2013 to get themselves ready to submit official filings. While taking on large data gathering efforts up and down their supply chains, most companies used the previous formats of the EICC-GeSI template.
Critical to their 2014 data gathering exercise will be the switch mid-stream to the new template format. This will cause some confusion as companies begin to send the new template out across their supply chains. This won’t be an easy or low cost task.
Some companies and associations hope for the regulation to go away and not have to worry about the data gathering exercise at all. There has been much talk lately about the National Association of Manufacturers filing of a lawsuit against the SEC stating the regulation violated a corporation’s First Amendment right.
The federal court disagreed. Here is an update from Deloitte on the federal court’s recent decision to deny the motion and find no fault with the SEC’s rule-making process.
So what does it have to do with Conflict Minerals Reporting Template 3.0, CMRT 3.0?
Publicly traded companies have to undertake an immense data gathering exercise. The work done by the EICC and GESI organizations has become the defacto standard for Conflict Minerals data gathering across many industries and at this time, it is the most unified way for corporations to exchange data up and down their supply chains. The biggest challenge is the aggregation of data collected with the template.
According to the Conflict Free Sourcing Initiative’s website, roll up capabilities are offered via the MRPRO dashboard. ” In collaboration with Papros, the CFSI offers a free software-based dashboard tool for data gathered via the Conflict Minerals Reporting Template. The MRPRO dashboard can aggregate multiple CMRT documents into one, export XML files of CMRT documents to be uploaded into proprietary databases or software solutions and perform some analysis tasks.” Click to get a copy of the CMRT 3.0 template.
Keep in mind, there are also many third-party solutions on the market that can automate your collection and roll up activities, as well as, create a due diligence trail that can be submitted for auditing purposes. One tool that I have personally been working with over the last year is offered by GreenStatusPro.
Bottom-line (don’t you hate when people say that?) many companies are done with their data gathering exercise for 2013 and with any luck, they are ready to report by the June 2nd, 2014 deadline. If your company still needs guidance developing a compliance strategy for Conflict Minerals, we’d be happy to help.
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