Many companies will have to rush to comply with a new regulation governing conflict minerals, a PricewaterhouseCoopers (PwC) study finds.
A quarter of companies surveyed in a PwC conflict minerals survey were still in the early stages of compliance: 26% were either finalising scoping, or planning and performing their reasonable country of origin (RCOI) inquiry, but had yet to evaluate RCOI responses.
“With 11% still in the product scoping stage, and with just over two months to the filing deadline, some respondents may have a rapidly narrowing window for action,” the report stated.
The survey comes after a conflict minerals rule was introduced in 2012, which requires SEC registered companies to disclose if their conflict minerals, which include tantalum (used in consumer electronics) tin, tungsten and gold, may have originated in the Democratic Republic of the Congo (DRC) region. If so, they have to determine whether these minerals in their products are conflict-free or not.
The rule was intended to provide consumers with guidance as to whether the products may be directly or indirectly linked to funding for armed forces involved in human rights violations in the DRC or surrounding countries (covered countries).
Affected companies must file a new Form SD and in certain cases, a Conflict Minerals Report, with the first filing deadline on 31 May 2014.
The study, conducted during February this year, gathered 700 responses from 15 industries, with participants varying in size from less than $1 billion in revenue to more than $20 billion.
Four main sectors – industrial products and manufacturing, technology, energy and mining and retail and consumer – accounted for 55% of all responses.
The survey found that many companies have full-time staffers assigned to conflict minerals, with 62% of respondents reporting that they have one to two full-time resources working on their conflict minerals compliance efforts. Some 21% indicated they have three to five full-time resources dedicated to this task.
Another key finding was that most companies will not require an independent audit in the first two years, either because they source their conflict minerals from outside the covered countries or because they expect those minerals to be DRC conflict indeterminable.
Companies are focused on compliance, but looking for opportunities to make the best of it, the report found. Of the respondents, 90% saw their efforts as a compliance exercise, but are simultaneously starting to see they can create benefits for everyone involved.
Almost half of the respondents have plans to become conflict-free, with 7% planning to do so within the next two years.
“Time is running out and companies need to move fast. Those that are just beginning to gather information and draft their filing are at risk of not only falling behind, but of missing opportunities in terms of supply chain improvements, competitive advantage and enhanced customer and stakeholder trust,” said Bobby Kipp, conflict mineral leader at PwC.