There's less than a year before companies must report on their exposure to so-called conflict minerals. Is your business ready?
The answer is no for almost half of U.S. executives who responded to a PricewaterhouseCoopers survey (PDF). Sixteen percent haven't started gathering data. And 32 percent of the 900 executives polled in the spring are still trying to figure out how the rule applies.
"There's no time to waste," said Bobby Kipp, partner in PwC's Risk Assurance practice."This can be an incredibly complex process and with the deadline fast approaching, companies will need to interpret the rule as best they can, and in a timely manner."
The Securities and Exchange Commission (SEC) 1502 rule that took effect in January requires public companies to start reporting in May 2014 on their sourcing of four so-called "conflict minerals" -- tantalum, tin, tungsten and gold -- that were mined in conflict areas or other abusive working conditions.
The minerals are found in thousands of products including cell phones, laptop computers, jewelry, golf clubs, drill bits and hearing aids. About 6,000 SEC-listed companies, and by association their supply chain partners, must start reporting next year.
"The most significant challenges that companies will face include identifying relevant suppliers, obtaining accurate and relevant information from them and establishing an entity-wide conflict minerals philosophy," Kipp said. "Companies should take these potential challenges into account when assessing their compliance timeline and project plan, and designing their conflict minerals approach."
The National Association of Manufacturers, the U.S. Chamber of Commerce and the Business Roundtable are trying overturn the rule, saying compliance will cost an estimated $3 billion to $4 billion. But so far that effort has failed.
Where's the right data?
One company seeking to help businesses that need to step up their compliance plan is Ecodesk, which develops management dashboards for energy usage, carbon exposure, water consumption, waste management and other sustainability metrics.
In early July, the company added a new conflict minerals module, which it says is already being used by several leading IT manufacturers. The software collects data from suppliers using the standard Electronic Industry Citizenship Coalition (EICC) declaration form. The information is automatically associated with a company's Ecodesk sustainability profile, and companies will be able to analyze conflict mineral exposure by geography, industry or individual smelter.
Right now, companies typically collect this sort of information using many spreadsheets. One big benefit for suppliers is that they will be able to direct all their customers to a single data source, easing their reporting burden. Likewise, the dashboard will allow companies to view information from multiple companies in one place, which will help them see which suppliers are using conflict-mineral-free smelters – and which are not. It is accessible either through a Web interface or via tablet computers.
"Our goal is to be an early warning system for non-financial factors in supply chains, providing businesses with a quick and clear understanding of potential problems before they occur," said Robert Clarke, founder of Ecodesk. "This is achieved through transparent sustainability data and disclosure of materials of interest, including conflict minerals. We are constantly updating our platform to provide new ways of easily managing and analyzing data and to offer increased connectivity between customers and suppliers, so that each can benefit from their mutual efforts towards greater transparency."
An Ecodesk subscription starts at $3,600 per year, enabling companies to track an unlimited number of suppliers.