New System Helps Companies Track Conflict Minerals for SEC Reporting

The Securities and Exchange Commission’s (SEC) new conflict minerals rule requires thousands of companies to perform due diligence to determine whether their products contain tin, tantalum, tungsten, or gold, determine the country of origin for those minerals and report their findings to customers and the SEC.

To assist with this complex process, Crowe Horwath LLP, one of the largest public accounting and consulting firms in the U.S., has introduced the Crowe Conflict Minerals Tracker. The solution is designed to provide an efficient but thorough method for administering the required supplier query, data collection and reporting processes.

The conflict mineral rule was mandated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The intent is to cut off funding to armed rebels responsible for human rights abuses in the Democratic Republic of the Congo (DRC) and adjoining countries where these minerals are mined and sold. To help with this effort, SEC registered companies now must conduct reasonable country of origin (RCOI) inquiries and other analyses and report on those findings.

“Crowe developed the Crowe Conflict Minerals Tracker to assist companies with RCOI surveys and supplier due diligence,” said Mari Reidy, partner in Financial Advisory Services with Crowe. “Using the Crowe Conflict Minerals Tracker solution as part of a comprehensive approach toward conflict minerals compliance simplifies data collection, analysis and reporting to be more efficient and strengthen results.”

Key benefits of the Crowe Conflict Minerals Tracker solution include:

  • Automated approach to centralized data collection that is designed to reduce duplicative requests and large spreadsheets;
  • “Parts wizard” function to identify products or components requiring an RCOI;
  • Web-based questionnaire distribution to simplify supplier tracking and communication;
  • Risk analysis dashboards to help track and review progress;
  • Export features to help transfer data to Form SD and a conflict minerals report; and
  • A built-in training video tutorial to walk users through the processes.

“With the challenges presented by conflict minerals due diligence and disclosure requirements, we knew that by using the forensic investigation knowledge of the Crowe team, as well as the manufacturing expertise available at the firm, we could provide a comprehensive, efficient solution,” added Reidy.


Source: Crowe Horwath LLP.