After EICC and GeSI agreed to expand the scope of their supplier questionnaire (i.e. the “EICC and GeSI Template”) to include product-level declarations, our RILA members decided that retail industry-specific training would ensure more accurate, complete responses to the questionnaire from suppliers and manufacturers. Throughout 2012, RILA and its members worked with Business for Social Responsibility (BSR) to develop effective and easy to understand retail-focused training for the EICC and GeSI Template. The training explains to suppliers Section 1502 of the Dodd-Frank Act, their due diligence requirements and how they should seek to identify conflict minerals in their supply chain. This retail training, along with the EICC and GeSI Template, was piloted with select suppliers in August and September of 2012. After gaps and issues were identified from the pilot, the training was adjusted accordingly.
The Securities and Exchange Commission (SEC) requires publicly traded companies that manufacture or contract to manufacture products for which conflict minerals are necessary to production or functionality to investigate the country of origin of the minerals in their products and to report to the SEC on their due diligence efforts with respect to products that contain covered minerals from the Democratic Republic of Congo or adjoining countries.
This document is intended to provide retail companies with:
(1) a summary of the SEC’s 3-step analysis, and
(2) guidance for retailers to use in understanding the critical phrases “contract to manufacture” and “necessary to functionality or production” as used by the SEC in the final rules.
Training and Educational Materials
The training and education materials include both fixed and customizable versions of the training presentation in English, Spanish, and Mandarin. The fixed version is a locked presentation, including a voiceover and both RILA and BSR logos. Retailers receive use of the logos but cannot make adjustments to the presentation. The customizable version is not locked and editable for adjustments by each retailer. It includes access to the raw files including voiceover scripts, presentations and voice recordings for each language. This customizable version does NOT include or allow use of RILA and BSR logos.
Access to the Materials
All materials are under license by RILA. If you are a member of RILA’s Conflict Minerals Compliance Project, then you can access the training materials. You can review the RILA license agreement for the materials here.
If you are NOT a member of RILA’s Conflict Minerals Compliance Project, then we welcome the opportunity to discuss project membership with you. Project membership will allow you to gain access to these materials and also will provide other project benefits. To learn more about joining this project, please contact Adam Siegel at firstname.lastname@example.org.