January 10, 2014 – January 17, 2014
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.

AICPA Issues New Guidance Regarding the Independent Private-Sector Audit

This week, the American Institute of Certified Public Accountants (AICPA) issued new guidance concerning the objectives of the independent private-sector audit, the criteria for independent private-sector audit as an attestation examination engagement, and evaluations outside the scope of an independent private-sector audit, among other things.

As a reminder, if an independent private-sector audit is required, the objective of the audit is two-fold, to determine (1) whether the reporting company’s due diligence framework conforms to the nationally or internationally recognized due diligence framework used by the reporting company; and (2) whether the reporting company carried out its due diligence in accordance with such framework.

Report: 42% of Companies Unprepared to Make Initial Form SD Filing Come May 2014

This past December, IHS, Inc., a global information company, conducted a webinar focused on the conflict minerals rule requirements. As part of the webinar, IHS issued a survey in which, according to Global Purchasing, 42% of the respondents answered either that they were not sure what to do to meet the rule requirements or that they had just begun to create a conflict minerals compliance plan. Approximately 140 companies participated in the survey.

In addition, the companies expressed their main concerns in complying with the rule, which include the effects of not complying with the rule and losing customers/clients as a result of their filings.

E&Y: Let’s Talk Sustainability Issue Focuses on Conflict Minerals

E&Y, a professional services organization, in its first issue of Let’s Talk: Sustainability, provides some background to the rule for those who are unfamiliar with the rule. E&Y also reminds its readers that although companies can file “undeterminable” as their status for at least the next two (2) years, this is not a “grace period” for companies to defer their investigation into their supply chains. Companies will have to show that they have made good faith efforts in investigating their supply chain and have built upon those efforts as future filings are made.