Ensure Conflict Minerals Due Diligence and Supply Chain Transparency
Certain minerals originating in the Democratic Republic of Congo (DRC) and adjoining countries have been a major source of concern due to their financing of armed groups accused of severe human rights abuses and of fueling regional conflicts.
Section 1502 of the Dodd-Frank Act addresses the problem of conflict minerals (tantalum, tin, tungsten, and gold, commonly referred to as 'CM 3TG') by setting requirements for due diligence, reporting, and public disclosure, and is designed to ensure accountability and discourage companies from doing business in ways that ultimately support exploitation and conflict.
SEC reporting and independent private sector audits (IPSA)
All issuers that are subject to Dodd-Frank Section 1502 are required to file a Specialized Disclosure Report, or Form SD, and depending on the origin of their conflict minerals or level of determination, issuers may need to submit a Conflict Minerals Report (CMR).
This reporting can be a complementary output of the third-party audit process.
The independent private sector audit (IPSA) of CMRs must be conducted in accordance with the requirements of the Generally Accepted Government Auditing Standards (GAGAS) as established by the U.S. Government Accountability Office (GAO).
With core values of integrity and ethics and an established history in impartial counsel, Bureau Veritas meets all GAGAS performance audit requirements and is fully prepared to provide independent private sector audits of Conflict Minerals Reports.
System gap assessments to prepare and ensure due diligence
As regulatory deadlines approach, organizations need to ensure that their conflict minerals due diligence systems are effective and meet Dodd-Frank requirements. Bureau Veritas offers to review due diligence systems to identify any gaps between organizations’ existing systems and the recommendations outlined in the OECD Due Diligence Guidance or a specific industry framework, such as the EICC CFSI Checklist.
Demonstrate compliance with recognized due diligence frameworks and chain of custody certification
Once due diligence systems are in place, Bureau Veritas provides Conflict Minerals Chain of Custody Certification and Third-Party Audits against industry standards and the OECD Due Diligence Guidance, respectively. Impartial audits and certification ensure consistency, accuracy, and reliability and demonstrate the highest level of commitment. Bureau Veritas is an approved auditor for the RJC, LBMA, and DMCC chain of custody standards.
LBMA Responsible Gold Guidance
Several robust initiatives have been taken to monitor the risk of financing conflict resulting from the purchase of minerals and metals (tin, tungsten, tantalum and gold) in conflict-affected areas such as the Democratic Republic of the Congo.
The London Bullion MArket Association (LBMA) has issued the LBMA Responsible Gold Programme based on anti-money laundering principles as well as the OECD Due Diligence Guide’s five step framework for risk-based due diligence.
Bureau Veritas Certification is one of the first Recommended Auditing Bodies for the LBMA Responsible Gold Guidance.
Responsible Jewelry Council Chain-of-Custody
The Responsible Jewelry Council, (RJC) an international, not-for-profit organization established to reinforce consumer confidence in the jewelry industry, launched its Chain-of-Custody (CoC) Standard and supporting documents for the precious metals supply chain in March 2012.
Bureau Veritas Certification is an Accredited Conformity Assessment Body for the RJC.
RJC defines responsibly sourced as:
- conflict-free as a minimum
- responsibly produced at each step of the supply chain.
DMCC Responsible Sourcing Review Protocol