What are the audit objectives?
There are two. The auditor must “express an opinion or conclusion as to
1. whether the design of the registrant’s due diligence measures as set forth in, and with respect to the period covered by, the registrant’s Conflict Minerals Report, is in conformity with, in all material respects, the criteria set forth in the nationally or internationally recognized due diligence framework used by the registrant, and.
2. whether the registrant’s description of the due diligence measures it performed as set forth in the Conflict Minerals Report, with respect to the period covered by the report, is consistent with the due diligence process that the registrant undertook.”
Will the IPSA Auditor provide an opinion of whether we’re conflict-free?
The IPSA Auditor will not provide an opinion of whether a filer is conflict-free. This is not among the audit objectives.
Will the audit evaluate the basis for our conclusions?
The filer will conclude that their product(s) contain one or more of the 3T&G minerals. This is the only conclusion that requires a IPSA Audit. The audit objectives do not require the IPSA Auditor to evaluate how the filer reached that conclusion. The IPSA Auditor should not include this as an audit objective, and will not include this in the audit report.
Other people (customers, etc.) are asking us for more information about the status of our conflict minerals. Can we have the IPSA Auditors audit other aspects of our program?
It is understandable that filers would want to have independent evaluations of other aspects of the IPSA compliance program. In fact, many companies are considering (or have obtained) audits of many aspects of their program, either at the insistence of customers, in response to requests by Non-Governmental Organizations (NGOs), or for risk management purposes. As auditors, we encourage audits! Consider, though, that the IPSA Audit is included as part of the filer’s Conflict Minerals Report. It is a financial filing, and it is public record. Nothing in the rule restricts the IPSA Auditor from auditing other aspects of conflict minerals management or risk; however, this effort should not be included in the IPSA Audit report.
Will the audit provide an opinion on our plans for next year?
A filer may include forward-looking statements in Management Discussion & Analysis section of financial filings. SEC has provided rules and guidance for these forward-looking statements. Similarly, a filer may include forward-looking statements in their Conflict Minerals Report – or elsewhere (for example, in their Form 10-K, or in Sustainability reports). The IPSA Auditor will not provide an opinion on forward-looking statements; it is not among the audit objectives in the final rule. As for including them in Sustainability reports – remember that Sustainability reports are not financial filings, so DFCM (or any SEC rule) do not apply.