The Responsible Sourcing Network has released a paper, the goal of which is to describe the content that certain sustainable and responsible investors, or SRIs, and nongovernmental organizations, or NGOs, expect to see in an issuer’s Specialized Disclosure, or Form SD, and Conflict Minerals Report, or CMR, if a CMR is deemed necessary. According to the paper it articulates key reporting components that are important to many SRIs and NGOs and suggests indicators that can be tracked over time to allow for comparability between reports and measure improvement.
Among other things, the group believes an issuer should describe the process it has in place and the steps it will take to:
- Identify risks in its supply chain.
- Ensure compliance with its policy and program. An issuer is expected to describe the steps it has taken to ensure that its suppliers are complying with the issuer’s conflict minerals policy and program.
- Respond to identified risks, including instances of noncompliance with its policy and program.
- Disclose and describe the contractual language, supplier-agreement language, and/or policies it is using to implement the steps above.
Check dodd-frank.com frequently for updated information on the JOBS Act, the Dodd-Frank Act and other important securities law matters.