Whilst we're on the topic of gold, found out something interesting coming out of the Dodd-Frank Act re: "Conflict Minerals" (Section 1502). I've got some interesting links here. The overview from KPMG seems to be a good start to understand it anyway.
kpmg.com
commodityonline.com
pcb007.com
Per the KPMG slides "The Act's intent is to try and curb the violence and exploitation in the Democratic Republic of Congo (DRC) and neighbouring countries by exposing companies that use minerals derived from this region through disclosure and public pressure"
"Metals covered commonly referred to as 3TG. They are Tin, Tantalum, Tungsten and Gold"
"A company will be impacted by this rule if:
- It files reports with SEC under the Exchange Act, and
- Conflict minerals are "necessary to the functionality or production" of its products manufactured
Even companies that don't file with the SEC may need to conduct due diligence on their supply chains, if they happen to be suppliers to impacted SEC filing companies
these metals are widely used in several industries including Electronics and Communications, Aerospace, Automotive, Jewelry,Health care devices, Diversified Industrial Manufacturing"
"Final rule is expected to be adopted by the SEC by April 2011. First reporting period is for fiscal year ending after April 15, 2012"
"Supply chain due diligence required by the Act:
Determine where 3TG metals are being used in products or processes at:
- in-house manufacturing
- Contract manufactures
Conduct supply chain due diligence, 3rd party verification, and in some cases private sector audits on the sources of these metals - all the way down to mine of origin.
Report out the findings of the due diligence on the company's annual SEC filings and website"
IMHO, a bit over the top for my taste, though I can understand the reasonings behind these provisions. The larger tech companies seem to have implemented some things currently (such as Apple and Intel)...IMO this piece of legislation will be particularly burdensome on the smaller companies...but I guess that goes without saying |
