With the initiation of the Dodd-Frank Act, companies need to determine if their products contain 'conflict materials' from certain global markets as the Rep of Congo. The materials include metals such as gold, tin, tungsten and tantalum. Compaines with global sourcing face new disclosure requirements in Feb'13 related to business being done in Iran. Public companies are required to disclose to U.S. security regulators if they or their affiliates are engaged in business in Iran either directly or indirectly. Is your supply chain compliant? Do you have sourcing reports to validate? Where are the materials in your chips & circuit boards coming from?
In the next few weeks, responsible companies will be scrutinizing their supply chains, subs, JVs, and affiliates to search for exposure.
Source: Brian Lane, Atty at Gibson Dunn Crutcher, as printed in the WSJ Tues, Dec 11, 2012 p.B8