Elm’s Self-Implemented Conflict Minerals Audit Preparation©
On June 13, SICMAP℠ was released for full commercial availability. Prior to that date, it was available only on a limited basis.
Lawrence M. Heim is leading the firm’s conflict minerals services: “We were confident that SICMAP℠ would be met with a good deal of interest in the marketplace. But we have been surprised at the response we are seeing in only the first two weeks of its launch. We have already received a commitment from one major player in the conflict minerals industry, and are in discussions with a number of Fortune 100 companies interested in SICMAP℠.”
SICMAP℠ focuses on basic program elements relevant to companies responding to customer inquiries/procurement requirements and those working to comply with the upcoming SEC regulations on conflict minerals. Successive steps are identified based on initial SICMAP℠ findings and the final regulatory requirements once they are known. The final rule, when published, will clarify the level of detail for some of the steps.
Some of the features and functionality in SICMAP℠ include:
• “At a glance” color-coding indicates progress/status
• Live links to reference materials on the internet
• Summaries of language from the U.S. legislation (which will not be changed by SEC’s final regulations)
• Highlights of emerging international initiatives in comparison/contrast to SEC audit standards
Topics covered in an intuitive and pragmatic way include:
• Initial scoping
• Reasonable assurance and representative sampling concepts reflecting SEC auditor standards
• Information management systems
• Internal controls
• Supply chain mapping
• Communications planning and content
• Scrap materials – special definitions and challenges in traceability efforts
• Considerations in selecting an auditor and preparing for the site visit
The tool is based on Elm’s experience as one of four firms worldwide that have completed conflict minerals traceability independent audits. Elm’s tantalum traceability audits in 2010 resulted in two of the three “Conflict-
* Issued by the industry association sponsoring the audits. The Conflict Free Smelter (CFS) program is emerging as the leading conflict minerals third party certification program for smelters by the electronics industry.
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Founded in 2001, The Elm Consulting Group International LLC provides health, safety, environmental and sustainability services with 11 offices (US, Mexico, Argentina, Venezuela, New Zealand, Indonesia, China) and over 100 affiliates in 22 other countries.