AICPA Conflict Minerals Resources 


    AICPA Guidance

    The AICPA Conflict Minerals Task Force has created and gathered the following information, in an effort to keep the AICPA membership informed and armed with the most up to date guidance.

     Guidance

    Blogs

    Read the AICPA's newest blog post on this topic "A Golden Opportunity: Performing IPSAs of Conflict Minerals Reports" at AICPA Insights.

    Webinars

    On October 9th, 2013, the AICPA presented an informative audio webinar "Conflict Minerals: What IPSA Auditors Need to Know." A no-CPE webinar replay is available at no cost.

    The above session was filmed at the 2013 AICPA Conference on Current SEC and PCAOB Developments and is presented here for replay.

       

    Background

    Among the provisions of the Dodd-Frank Act are mandated disclosure rules, passed by the Securities and Exchange Commission in August 2012, about the use of “conflict minerals”. The term “conflict minerals” is used to describe certain minerals—tantalum, tungsten, tin, and gold—that are mined in the Democratic Republic of the Congo (DRC) or the surrounding areas. Federal law does not prohibit companies from sourcing conflict minerals, nor impose a penalty for doing so. However, the intent is to rely on public pressure to dissuade U.S. companies from indirectly sourcing conflict minerals, and hence fund the armed groups in the DRC.

    The SEC final rule requires issuers who use conflict minerals in their manufacturing processes and supply chain to disclose whether the minerals came from the DRC or the surrounding areas. Under the rule, if a company determines its conflict minerals originated in those countries, it will have to file a “Conflict Minerals Report” with the SEC and publish it on its website. The reports, which will outline to the SEC all of the due diligence the company performed as it sourced its supply chain, must be independently audited.

    The provision specifically mandates three steps for companies to follow:

    1. Determine if tin, tungsten, tantalum and gold are used to make its products.
    2. Determine if the metals they use originated in the DRC or neighboring countries. If the metals did not originate in affected nations, companies must report how the company determined the metals’ origins.
    3. If the metals were from DRC or adjoining countries—or the source is unknown—companies must trace the supply chain for the source and furnish “Conflict Minerals Report” (CMR) on those due-diligence efforts

    Under the rule, companies will file their first specialized disclosure report on May 31, 2014, for the 2013 calendar year and on May 31 in subsequent years.

    Independent Private Sector Audit (IPSA)

    The purpose of the IPSA is to express an opinion or conclusion as to: (1) whether the design of the issuer’s due diligence framework as set forth in the Conflict Minerals Report is in conformity with, in all material respects, the criteria set forth in the nationally or internationally recognized due diligence framework used by the issuer, and (2) whether the issuer’s description of the due diligence measures it performed as set forth in the Conflict Minerals Report is consistent with the due diligence process that the issuer undertook.

    The independent private sector audit is required to be performed in accordance with the “Yellow Book” and can consist of either an examination attestation engagement or a performance audit.

    The AICPA has convened a task force to provide practitioners with guidance relating to the IPSA.

    Other Useful Links

    Rules, Frameworks, and Other Tools

    Articles and Other Resources

    For more information on the AICPA's involvement with the issues surrounding Conflict Minerals, contact Ahava Goldman at agoldman@aicpa.org or 212-596-6056.




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