The Elm Consulting Group International LLC today announces a groundbreaking cost effective tool to support companies preparing for conflict minerals traceability audits or customer inquiries.
The delay in SEC’s final rule triggered many questions from companies about planning and pre-audit preparation. This led us to a solution that is valuable in almost any foreseeable final regulation scope/content and companies planning responses to customer inquiries – yet significantly reduces costs during this period of uncertainty.
Elm’s Self-Implemented Conflict Minerals Audit Preparation© (SICMAP℠) is conceptually similar to a self-audit checklist. SICMAP℠ is a spreadsheet tool that maximizes the use of internal company staff for cost reduction and implementation flexibility to develop and review conflict minerals programs in advance of third party auditing.
SICMAP℠ focuses on basic program elements equally relevant to companies responding to customer inquiries/procurement requirements and those working to comply with the upcoming SEC regulations on conflict minerals. Successive and more complex tasks – for both program development and audit preparation – are identified based on initial SICMAP℠ findings, lessons learned from working through the SICMAP℠ process, and the final regulatory requirements once they are known. The final rule, when published, will clarify the level of detail for some of the efforts.
Screenshots (which can be enlarged by clicking on them) show some of the features and functionality in SICMAP℠ include:
- “At a glance” color-coding indicates progress/status of both program development and audit preparation
- 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)
- Step-by-step pragmatic guidance on specific program elements
- 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 the first ever “Conflict-Free Smelter” designation*, covering sites in the US and Japan.
We continue to recommend that companies move forward with planning activities, but defer third party audits until planning is substantially complete and the SEC regulations are final. As with almost any new management program, a formal third party audit should be the last step of the implementation process – not the first.
SICMAP℠ will be commercially available beginning June 6, but feel free to contact us beforehand with questions.
* 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.