When the US Securities and Exchange Commission’s conflict minerals rule was issued in 2012, US reporting companies (and their suppliers) developed and implemented conflict minerals compliance programs. Companies have continued to enhance and beef up their programs since then. Now, companies should be supplementing their compliance programs to be ready to address the requirements of the EU conflict minerals regulation when it is finally adopted.
The EU regulation, as currently proposed, will impact hundreds of thousands of European companies – many more than are covered by the US rule. And the proposed EU regulation has a much wider geographic focus than the US rule. So, what steps should a company take to develop its initial conflict minerals compliance program? Or what steps should a company take to quickly expand its existing compliance program to fulfill the likely requirements of the EU regulation?
You should consider some best practices in building your own compliance program. We’ve attached some topic areas to keep in mind. You can use them to organize your planning.