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JVC Creates Supply Chain Assurance Kit for Dodd-Frank Provision

Jan 8, 2014 1:31 PM   By Jeff Miller
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RAPAPORT... The Jewelers Vigilance Committee (JVC) created a ''Supply Chain Assurance Kit'' to help the industry navigate the  “conflict-free”  mineral source provision often required by industry consumers of gold and tungsten products as a result of Section 1502 of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act.

Dodd-Frank requires that public companies disclose, through a filing with the Securities and Exchange Commission (SEC), if any of the products they sell that are made with gold or tungsten are not “conflict free.”  Therefore, every company in the direct or indirect supply chain of SEC-listed companies will need a supply chain assurance system to make this determination, according to the JVC.  They will also need to communicate their commitment to their responsible supply chain and details about their assurance system, to their customers.  Forms to use for this purpose are also available in JCV's kit. 

JVC created the kit in a do-it-yourself format and to provide assurance to customers of gold and tungsten  that the minerals are conflict free.  JVC’s kit was created based on standards issued for this purpose by the Organisation of Economic Cooperation and Development (OECD) for responsible supply chains.  OECD is a non-profit UN affiliated agency that promotes economic and social well-being for people around the world. 

The JVC assurance system consists of several elements, including creating strong management systems to control the supply chain for these minerals, a risk assessment and a management strategy to address any identified risks.  For many sellers of tungsten or gold, or products made from these minerals, the key to compliance is the ability to determine that the gold purifiers or tungsten smelters or suppliers of these products in their supply chain have implemented their own supply chain assurance system.  JVC’s kit includes all necessary templates and guidance to implement supply chain assurance and make the required inquiries and assurances for both gold and tungsten.

Since system requirements will differ depending on where a company exists  on the mineral supply chain, and whether it is supplying gold or tungsten, JVC customized its kits' guidance and templates to meet those various  obligations created by Dodd-Frank.  The kit also includes an explanation – and examples – to help users determine their position on the supply chain and exactly which kit materials to use. 

Cecilia Gardner, the CEO and president of JVC, said,  “Like JVC’s USA Patriot Act Compliance Kit, JVC’s new Supply Chain Assurance Kit will become the industry standard to implement a system that assures that the gold and tungsten you supply is ‘conflict free.’ Although the kit is designed as a do-it-yourself tool, JVC’s experts are available to help you implement the system for your supply chain to assure that you can continue to supply these products to any company in the supply chain of a publicly held company. JVC experts are also available for staff training and consulting.”

JVC priced the kit at $100 for members and $250 for non-members and is taking orders via telephone at 212.997.2002. JVC expects to enable online orders soon.

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Tags: compliance kit, conflict minerals, dodd-frank, guidance, Jeff Miller, JVC, SEC
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