The first wave of Form SD filings has come and gone, leaving us with more insight into supply chains and manufacturing processes than most of us ever wanted, yet much uncertainty about the actual sources of the conflict minerals in question. Not surprisingly, most companies that filed a Form SD were unable to confirm whether their conflict minerals came from the Democratic Republic of Congo (or its neighbors) or whether their purchase of conflict minerals financed armed conflict.

Many filers are understandably burnt out on the whole process and are happy to forget about it until the next filing deadline (May 31, 2015). And those lucky enough to have determined that no Form SD filing was required in 2014 may be tempted to forget about the issue altogether. Regardless, however, of your company’s 2014 status (filer or non-filer), forgetting is not acceptable.

Business operations are fluid. Product lines change, as do manufacturing processes, suppliers and product uses. Furthermore, chances are that additional work must be done to follow up on incomplete or non-existent responses to your “reasonable country of origin” inquiry or to fill other holes in your inaugural conflict minerals review process.

 

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