This CFSI white paper provides companies and other stakeholders with useful approaches and clear, practical steps to improving their company’s conflict minerals program. It reflects the latest thinking about the relationship between the OECD Guidance and the SEC Rule and suggested activities companies may undertake when implementing their compliance programs. For example, the paper discusses some critical distinctions between companies with direct supplier relationships with smelters and refiners, and those companies that are many supply chain tiers away. Approaches to risk assessment and the impact that assessment has on a company’s next steps is further outlined. Finally, the process for defining conflict-affected and exemplary steps to mitigation is discussed in detail.
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