The following minerals have currently been identified as conflict minerals, but this list may expand in the future:

• Columbite-tantalite (the metal ore from which the element Tantalum is extracted)
• Cassiterite (Chief ore needed to produce Tin)
• Wolframite (Important source of the element Tungsten)
• Gold (Used widely in electronics, semiconductors, dental products, jewelry)

If the minerals did originate in the DRC countries, the company would be required to furnish a separate report as an exhibit to its annual report that includes, a description of the measures taken by the issuer to exercise due diligence on the source and chain of custody of its conflict minerals.

If an issuer declares that its conflict minerals did not originate in the DRC countries, the issuer should in the body of its Annual Report, disclose this determination and the reasonable country of origin inquiry process it used in reaching this determination.

The challenges

The new regulation will bring in new challenges for supply chain groups within companies, as tracing the source of minerals, particularly those contained in bought out parts, assemblies or other items purchased from vendors is going to be an uphill task. The fact that the supply base is not geared to address this only magnifies the challenge.

Enventure’s services

As an industry leader in the compliance space, Enventure is one of the first companies to offer services to support companies that need to comply with the new regulation. The services are structured as comprehensive solutions, and are designed to reduce the additional work load on supply chain groups, brought on by the regulation. The service portfolio includes the following services:

• Supplier Training
• Develop compliance road maps
• Consulting and gap analysis
• Collection of required data and/or declarations from Suppliers
• Ongoing maintenance of supplier declarations