December 13, 2013 – December 20, 2013
The summaries provided in this Weekly Recap do not necessarily represent the views of Squire Sanders (US) LLP and should not be deemed to be endorsements of them. The Recap is intended to be a compilation of articles and events to encourage discussion within the conflict minerals community and to keep our readers updated on the most recent developments.
AIAG’s Conflict Minerals Reporting Checklist
The checklist is aligned with the OECD’s due diligence guidance and is designed for reporting companies, but can be modified to fit your own company’s facts and circumstances.
According to its website, the AIAG is a not-for-profit association whose stakeholders “work collaboratively to streamline industry processes via global standards development & harmonized business practices.” It was founded in 1982 by the three largest North American automotive manufacturers – Chrysler, Ford, and General Motors.
Op-Ed: Think You’re Not Part of the Congo Conflict? Check Your Pocket
Paul Dewar, a New Democratic Party Member of Parliament for the riding of Ottawa Centre, wrote an opinion editorial in the Huffington Post Canada’s blog titled Think You’re Part of the Congo Conflict? Check Your Pocket.
In his op-ed, Mr. Dewar stresses that conflict in the Congo is not Africa’s problem, but everyone’s problem. That is why he (Mr. Dewar) introduced the Conflict Minerals Act in the House of Commons in March 2013. Mr. Dewar concludes by stating, “The time is right for significant change. Minerals may be everywhere, but conflict doesn’t have to be. Just as people can now give ethical diamonds, we should be able to give electronics and jewellery [sic] in good conscience. Together, we can take conflict out of Canadian homes, and, in doing so, out of the Congo. That really would be a wonderful gift.”
Compliance Week: The Problem Underneath Conflict Minerals Compliance
Matt Kelly of Compliance Week in his latest article titled The Problem Underneath Conflict Minerals Compliance unearths one of the main issues companies are facing as they comply with the conflict minerals rule (and any other regulatory rule): the constant badgering of their suppliers for more information.
Kelly elaborates, “Compliance pressures that hit your third parties are proliferating so rapidly—anti-corruption, conflict minerals, data security, human trafficking, offshore tax havens—that they now exceed your ability to manage them all well, or in any systematic fashion. The result: you keep pestering your third parties one regulation at a time, to the point where they get compliance fatigue and don’t want to cooperate with you. A Chief Legal Officer of a large manufacturer agreed, stating, ‘It’s a big ask we’re imposing on them, and we need to find a way to ease that up.'”
To remedy this problem, some companies are looking to software programs to assist them in streamlining all of their compliance communications with suppliers.