Douglas Hileman Consulting LLC (DHC) provides this tip sheet on the Government Accountability Office’s (GAO) third annual report pursuant to Section 1052 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The report is titled “SEC Conflict Minerals Rule: Companies Face Continuing Challenges in Determining Whether Their Conflict Minerals Benefit Armed Groups ” (2016 GAO Report).
The 2016 GAO Report summarizes companies’ SEC submittals for the 2014 reporting period; by GAO’s press time, the 2015 submittals were in, and several organizations have published their summaries of the newest (and third) batch of submittals. The GAO Report highlights continuing challenges in the conflict minerals supply chain, and takes the Department of Commerce to task for not fulfilling some statutory mandates regarding due diligence and the Independent Private Sector Audit (IPSA).
DHC believes the GAO report includes two sections that are misleading or unsupported. DHC’s perspective on these two issues are outlined in a white paper titled: GAO's Third Report on Conflict Minerals "Companies Face Continuing Challenges..."" An Analysis.