After U.S. courts refused to move back the filing deadline for conflict mineral disclosures, in-house legal departments in companies that use key minerals often connected to the Democratic Republic of Congo (DRC) are scrambling. But now, just a few weeks ahead of the June 2 deadline, the first tech company has submitted its report: Intel.

On May 22, Intel submitted its Conflict Minerals Report (along with its Form SD) to the Securities and Exchange Commission (SEC) detailing the company’s efforts to keep its supply chain conflict mineral-free. In the report, Intel describes the design of its Conflict Minerals Program, as well as the limitations of said program.

As a result of its internal investigation, Intel concluded that “the necessary conflict minerals contained in our products that originated or may have originated from the Covered Countries are either DRC conflict free or DRC conflict undeterminable.” Intel claims that some products are undeterminable because the company does not have “sufficient information from suppliers or other sources regarding all of the smelters and refiners that processed the necessary conflict minerals.”

Following new government guidelines that mandate an independent auditor look at the company’s practices, Ernst & Young also examined the company’s procedures for conducting due diligence in its Conflict Minerals Program. Ernst & Young made no determination whether the company used conflict minerals in its supply chain.

Perhaps it is unsurprising that Intel was the first to file its Conflict Minerals Report, as the company has been outspoken against the use of conflict minerals in its supply chain. As the company said in a February 2014 release, “From the time we became aware of the potential for conflict minerals from the DRC to enter our supply chain, we have responded with urgency and resolve.”

Other companies that use four key minerals typically found in the DRC — tin, tantalum, tungsten and gold — now have only a few weeks to follow Intel’s lead.


For more on our ongoing coverage of conflict minerals disclosure, check out these recent stories:

Court keeps conflict minerals filing deadline in place

U.S. court says SEC’s conflict mineral ruling violates freedom of speech

The art of conflict minerals compliance 

EU drafts conflict mineral compliance regulation