I had the pleasure last week of talking to a top legal officer at a large manufacturer, someone who will be speaking at the Compliance Week 2014 conference next spring about conflict minerals compliance. The program his company has developed so far is excellent, and I won’t spoil it by naming him and disclosing all the details here—but our conversation also underlined a headache compliance executives are facing that runs far deeper than conflict minerals, one worth discussing now.
Let’s start with our man Smith and his company’s first efforts at conflict minerals compliance. The duty fell to Smith because he, in the legal department, oversees all regulatory filings with the Securities and Exchange Commission—which will include conflict minerals disclosure on the agency’s new Form SD, starting early next year. So Smith assembled a task force from various company departments: compliance, accounting, IT, and supply chain.
