The Government Accountability Office, or GAO, has issued a report noting the SEC issued a rule in 2012 requiring certain companies to disclose the source and chain of custody of necessary conflict minerals in their products. However, the report notes the Department of Commerce has not yet compiled a list of all conflict minerals processing facilities—smelters and refiners—known worldwide, required by January 2013 pursuant to the Dodd-Frank Act. Commerce cited difficulties with, for example, tracking conflict minerals operations but told GAO that it had completed outreach efforts with the majority of stakeholders. According to GAO Commerce did not have a plan of action, with associated time frames, for developing and reporting on the list of conflict minerals processing facilities worldwide. The GAO said standard practices in program and project management include, among other things, developing a plan to execute specific projects needed to obtain defined results within a specific time frame. The GAO thinks an action plan with timeframes could better position Commerce to report on the status of its efforts to produce a final list to Congress and to hold its personnel accountable for completing activities.
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