Special Disclosure (FORM SD) For Conflict Minerals (CMRT)
SD for CMRT
Companies are affected by this regulation if they are listed on the US stock exchange. And if the company uses components or raw materials in their products which contain Tin, Tantalum, Tungsten or Gold (3TG), a detailed due diligence program is required to ensure compliance.
Even companies which are not publicly traded are affected by the Conflict Minerals regulation, as the entire supply chain of an SEC regulated company will be asked to provide Conflict Minerals reports using the CMRT template, and this mandate cantrickle down the supply chain multiple levels.
Conflict Minerals Report
The process of collecting and analyzing conflict minerals compliance data is quite time-consuming, and can take weeks to months to complete, depending on the number of suppliers. The task becomes even more challenging if you have been sourcing from new suppliers who are unaware of the importance of CMRTs.
SEC Conflict Minerals Disclosure requirement
- Reasonable Country of Origin Inquiry (RCOI)
- Risk assessment, due diligence process, company management system, and risk management strategy
- Smelters or refiners’ disclosures, including efforts taken to locate the mine of origin.
- All measures taken since the previous reporting period and future measures planned to improve the Conflict Minerals due diligence program.
