Many of you are aware of, and some of you have participated in, Tulane’s anonymous conflict minerals post-filing survey, which aims to reveal the realities of Dodd-Frank Section 1502 regulatory compliance.
So far, 132 companies have participated, with 75 of those from issuers or issuer and Tier 1 suppliers, ranging from the $50-100 million revenue to $50-100 billion annual revenue thresholds.
We are urging additional companies to participate. We believe the information collected and analyzed by the survey, which only takes a company representative an average of 20 minutes to complete, will be very useful to manufacturers as they plan for reporting in future years. The survey findings could allow you to benchmark and compare yourself to other companies of your size and in your industry, especially with regard to the following:
- How much are other companies paying for consultants? (new internal vs new external human resources)
- What IT system/software needs and expenditures are other companies experiencing? (industry type versus IT costs)
- How many new hires and in which departments are companies engaging? (size/new employee ratio)
Because this research is not sponsored by any stakeholder group, but conducted by an impartial, academic party, the findings will be credible and will be widely disseminated.
Please note that at the end of the survey, you will have a chance to recommend changes to the law or regulation. For example, we’ve been told that some companies have stated that they would like to see a de minimis exemption added. You will also be able to provide an example of a best practice your company has implemented as part of the compliance scheme.
In order for the study’s findings to be meaningful and representative, participation of at least 297 issuers of the roughly 1,308 total affected issuers, and at least one of their Tier 1 suppliers each, is required. The study will remain open for participation until that sample size is reached. The online survey link is here, and the password is: JULY2014.
The survey is anonymous, unless your company would like to reveal its identity.