Experts Look to Managed Services to Mine Minutia for Conflict Minerals Reporting
Electronics, aerospace, automotive and other manufacturers and suppliers look to global supply chain info-gathering expert STTAS to meet SEC requirement.
Detroit, MI… With the May 2014 deadline to notify the Securities and Exchange Commission of the use of conflict minerals in any part of their operations fast approaching, manufacturers are looking outside their own organizations for solutions to the daunting task.
“The reach of this requirement touches a broad array of industries and creates overwhelming compliance challenges for thousands of companies,” explains Kevin Smith, Senior Vice President of Strategic Programs for leading international trade managed services provider Sandler & Travis Trade Advisory Services, Inc. (STTAS). “The idea of accessing your entire supply chain to determine the origin of the minerals that were used to create each component of a finished product is hard enough,” he says. “Now multiply that problem by dozens or even hundreds of different products, and you end up with the kind of challenge that keeps compliance officers and global trade executives up at night.”
Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires publicly-traded companies to conduct upstream due diligence investigations of their suppliers’ sourcing practices and disclose their use of certain minerals originating in the Democratic Republic of Congo or adjoining countries. Designed to draw public attention to the armed conflicts and human rights abuses associated with the trade of the so-called 3TG minerals—tantalum, tin, tungsten and gold—Section 1502 has put companies in the position of having to seek out information from sources that can be hard to locate and even harder to communicate with, Smith says.
As the former General Director of Global Customs for General Motors Corporation, Smith was responsible for tracing country of origin documentation to prove compliance with complex trade programs such as the North America Free Trade Agreement, which requires delving into the most intricate details of the manufacturing process. Smith turned to STTAS and its cost-saving combination of automated systems and expert trade analysts to help with that process. He says the same expertise that managed these complex trade matters is now being directed toward helping companies comply with Dodd-Frank conflict minerals reporting.
“STTAS’ experience working in the manufacturing realm, its unsurpassed domain expertise in the international trade arena, and its ability to solicit, retrieve, interpret and verify complex trade-related data make it a perfect fit for manufacturers with deep supply chains,” says Smith. “STTAS is now reaching out to manufacturers and their OEM suppliers to leverage this same data solicitation, retrieval and reporting expertise to help them meet their conflict minerals reporting requirements.”