In 2014, HR4173, the Dodd-Frank Financial Reform Bill Section 1502(b) went into effect and publicly-traded companies now have the requirement to report on whether or not their supply chain is Conflict Minerals free. US stock listed original equipment manufacturers (OEMs) who outsource now have one more area to evaluate in supplier selection. Has their selected electronics manufacturer services (EMS) provider invested in the infrastructure to support supply chain due diligence or does it instead, expect its publicly-traded customers to handle that due diligence as part of the approved vendor list (AVL) development?
This paper looks at key issues and costs drivers in this equation and the industry-driven systems that can help minimize the additional costs associated with the necessary due diligence. It also looks at the choices SigmaTron International, a publicly-traded U.S. EMS provider, has made in developing a compliance system that meets both its needs and the needs of its publicly-traded customers.