Il 22.8.12 la SEC ha approvato la norma sui “Conflict Minerals”. La normativa prevede l’obbligo di produrre un compliance report sull’origine dei minerali utilizzati nel ciclo produttivo. Molti dei "Conflict Minerals” sono comunemente utilizzati in beni di consumo e di produzione industriale e la SEC stima che circa la metà di tutte le società quotate sarà tenuta a presentare una relazione annuale. Allo stesso modo, i fornitori di queste imprese (anche se non quotati) dovranno presentare ai loro clienti una documentazione del tutto simile.

1. OVERVIEW OF CONFLICT MINERALS REGULATION
The SEC’s final ruling on Conflict Minerals, which was issued on August
22, 2012, will affect public reporting for thousands of companies and
attempt to bring significant transparency to their supply chains. While
the SEC reporting requirements directly impact only SEC registrants, it is
anticipated that non-public companies that are suppliers to impacted
companies will also need to comply. Additionally, the EU Trade
RESOURCES Commission has been studying this topic and advised in late 2011 that a
AT A GLANCE communication on Conflict Minerals would be issued.
A global professional services firm
with a Big Four heritage: What are they and why is action being taken now?
45 of the Fortune 50 served
100% retention of top 50 clients The term conflict minerals refers to columbite-tantalite (tantalum),
Served more than half the
wolframite (tungsten), cassiterite (tin) and gold. These minerals are
Fortune 1000
Consultants have 15-20 years’ commonly referenced as 3TG. Their profits are widely acknowledged to
experience finance conflict within the Democratic Republic of Congo (DRC) and
3,000 professionals in 77offices adjoining countries. While these minerals are not all household names,
A high-value, cost-effective they are ubiquitous in this global and electronic age. They can be found
business model
in common consumer products such as jewelry, mobile phones,
computers, digital cameras and other items that use electronic circuits
and components as well as in packaging, pesticides and zippers.
The Conflict Minerals Provision, Section 1502 of the Dodd-Frank Act,
aims to create transparency that will encourage companies to source
only conflict-free minerals.
What’s next?
Now that the Provision is finalized, SEC Registrants will have to make the
necessary disclosures in conjunction with their annual financial filings.
The first Conflict Minerals Report for all companies is due on May 31,
2014, for the calendar year January 1 - December 31, 2013. The effort
required to fully comply could require many months of work.

2. COMPLYING WITH CONFLICT MINERALS REGULATION
Is your organization impacted?
Review the following steps to determine if the requirements of the Dodd-Frank Act apply to your business:
STEP 1 Are you an SEC 13(a) or 15(d) “Issuer”?
Determine Do you manufacture, or contract to manufacture products containing conflict minerals?
Applicability Are conflict minerals necessary to the functionality or production of the product manufactured by or
for you?
STEP 2 Due Conduct a Reasonable Country of Origin Inquiry (RCOI)
Diligence Using an acceptable framework (i.e., Organization for Economic Cooperation and Development
(OECD)), determine source and chain of custody of conflict minerals
Determine whether conflict minerals are from Covered Countries, scrap or recycled; describe
methods and results
STEP 3 Prepare either a Form SD or a Conflict Minerals Report and a Form SD describing the measures taken
Compliance in Due Diligence
Reporting Obtain and certify an independent third-party audit and report on methods and results
Disclose conflict minerals determination through filing Form SD and posting on publicly available
company website
Note that Suppliers to SEC 13(a) or 15 (d) “Issuers” should expect to be asked to provide information on the source of 3TG
minerals in their products.
How Resources can help QUICK DIAGNOSTIC DUE DILIGENCE
We have assisted thousands of Mapping of Supply Chain Determine Applicability
Review of Bill of Materials Reasonable Country of Origin
clients with complex and Review of Supplier Contracts Due Diligence
significant compliance initiatives. Overall readiness assessment Generate Conflict Minerals Report
Our Consultants’ possess an
average of 15-20 years of Resources Global can manage all related content, including supplier contracts,
readiness assessments, due diligence documentation and checklists, and ongoing
experience in both consulting and
audits in our proprietary content management software, policyIQ.
corporate roles, which enables us
to provide a unique and cost- INDEPENDENT AUDIT TRAINING
effective alternative to using Issue certification on: Customized training for client
o Appropriateness of the resources
traditional consulting and design Focuses on Reasonable Country of
accounting firms. We can partner o Accuracy of the description Interest and Due Diligence approach
with your internal team or of the due diligence Prepares clients for Year 1 and
measures ongoing, sustainable compliance
provide a team to help lead this
significant endeavor.
Resources Global Professionals (Italy) S.r.l.
Foro Buonaparte, 59 - 20121 Milano
Tel: +39 0289097121
The world’s leading businesses trust Resources Global with their most pressing initiatives. E-mail: info@resourcesglobal-it.com
Our accomplished professionals have expertise in finance & accounting; information www.resourcesglobal.com
management; governance, risk & compliance; human capital; legal & regulatory;
corporate advisory & restructuring; strategic communications; and supply chain
management. Founded in 1996, we are the operating subsidiary of Irvine, California-
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