The report considers the lessons learned thus far and how they can be applied to a holistic compliance program covering a wide range of regulations, not just those relating to conflict minerals. It also examines the way in which companies have complied with the regulations in the first reporting period. It includes case studies of companies that have been working on conflict minerals – offering insights into challenges, lessons learned, and ideas for developing a conflict minerals program.
The annual filing of a conflict minerals report to the SEC is not the end of the matter. Companies can expect to see increased pressures for supply chain transparency and having to meet stricter disclosure requirements in the future. KPMG recommends filers should not regard conflict minerals compliance merely as a box-ticking exercise, but as an opportunity to build a supply chain program in which the links between different regulations are clearer and the management of regulatory risk is made more coherent.
- Companies should set up systems and processes to meet increasing demands for supply chain transparency.
- A risk-based approach to compliance should help companies to gain deeper insights into their supply chain and to optimize their operations. A little knowledge of the supply chain is a dangerous thing; knowing more can only improve the way to run a business.
- By integrating conflict minerals reporting compliance with other regulations, companies should be able to see how regulatory risks are connected. A holistic approach to compliance will improve efficiency and help companies to manage risk more effectively.
- An integrated review of filings reduces the risk of inaccurate reporting and thus the risk of non-compliance; accurate reporting should help compliance.
- The risk of being found non-compliant with an important regulation affects a company’s reputation. A rigorous approach to conflict minerals can enhance a company’s reputation.