Here on the policyIQ team, we are always talking about how we love a good challenge – and Dodd-Frank’s Conflict Minerals provision has provided us with challenges in spades. We are learning to be careful what we wish for!
If your company is subject to the Dodd-Frank Conflict Minerals rules, you are likely well-aware of some of the challenges that organizations like yours are facing. The regulation requires that any publicly listed company who manufactures (or contracts to manufacture) a product containing Tin, Tantalum, Tungsten or Gold – referred to as 3TG (also a great name for a boy band) – trace the origin of those minerals to the source, reporting on whether the minerals originate from the Democratic Republic of the Congo or some surrounding countries.
Survey your suppliers! Wait…how many suppliers do you have?
After identifying those suppliers who may supply products containing one of the 3TG minerals, the next step for most organizations is to conduct a Reasonable Country of Origin analysis – typically involving sending a survey out to those identified suppliers.
Surveys and policyIQ go together like chocolate and peanut butter, so we know we have that survey part covered!
The challenge, of course, is the aggregation of responses on every unique part that a supplier supplies. Consider an organization with over 300,000 unique parts supplied to them that may contain one of the 3TG minerals – and you can understand the challenge of effectively capturing, aggregating and reporting on that data.
policyIQ continues to perform faster for ALL of our clients
In addition to building unique functionality to manage the aggregation of large amounts of part-level data – our policyIQ development team has also been busy working to optimize the entire application, so that handling half a million (or a million) records becomes child’s play. In fact, we’re close to releasing version 7.1, with even more functionality and performance enhancements than the just-released version 7.0. (policyIQ clients who have not yet upgraded from version 6 will always be upgraded to the latest and greatest version of policyIQ!)
Table filters – introduced in version 7.0 – become essential, so that a conflict minerals project manager can filter out the relevant responses for follow-up. Bulk changes – to update status or follow-up actions – are performed on thousands of records at a time.
The best part? Every policyIQ client benefits from these improvements.
So if anyone asks you if you are impacted by Dodd-Frank’s Conflict Minerals regulation, you can accurately say, “Yes!” – even if that impact might just be in the technology enhancements you enjoy as a policyIQ client.
Let our experienced Conflict Minerals team help you
RGP has put together an incredible team of experienced professionals who have gone through the Conflict Minerals compliance process with organizations across the country. Reach out to us and we’ll put you in touch with the regional expert to help you understand the impacts and put a plan in place for your compliance program!