Much of the conflict minerals compliance focus has been on U.S. publicly traded companies in meeting the requirements imposed by the Securities and Exchange Commission. However, thousands of more companies that are not subject to SEC rules are, in fact, facing possibly greater federal scrutiny related to the conflict minerals issue.
Inherently, the issue of conflict minerals extends far beyond determining whether a product may contain one or more of the four key raw minerals that are mined in the Democratic Republic of the Congo to help fund a deadly civil war in that country. The underlying factors behind the enactment of Section 1502 of Dodd-Frank deal with corruption, modern day slavery and human rights. Companies large and small that are providing services or products to the federal government face all of these issues and more when meeting federal contract terms and through auditing.
“The Federal Acquisition Regulation is perhaps the most far-reaching and complex federal contracting requirement,” A government contracting expert at Source Intelligence. “Any company linked to federal procurement – either under direct contract with the U.S. government or supplying those companies – are subject to federal audits, investigations and more.”
The general principle for companies and suppliers to follow is to “act” as if they are subject to the SEC rules for conflict minerals disclosure, even if they are not a publicly traded company. The due diligence involved in determining if a product contains conflict minerals provides an optimum framework to track, analyze and report on the connected issues – human trafficking and human rights violations, corruption, restricted substances and more.
Minerals Tracking and Reporting System
Source Intelligence’s comprehensive SaaS platform provides suppliers and companies with a unique enterprise solution that enables a single tracking and reporting system covering multiple compliance requirements. Source Intelligence’s system is supported by technical experts, which include federal contracting specialists who provide one-on-one counseling to customers.
Additionally, OEMs bidding on government contracts often scan their databases for suppliers who already meet FAR or similar federal contracting laws. Suppliers not capable of meeting FAR reporting requirements or with a history of taking too long to compile and file reports are often the “second choice” for many companies.
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