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Blog

Supply Chain and ESG – What You Need to Know: Responsible Minerals, Supply Chain and ESG

I recently had the opportunity to visit with several folks from Assent Inc. for a sponsored podcast series entitled Supply Chain and ESG – What You Need to Know. We discussed: ESG drivers with Jared Connors and James Calder; UFLPA, Supply Chain and ESG with Travis Miller and Jamie Wallisch; the New World of Product Compliance and ESG, with Cally Edgren and Devin O’Herron; Emissions Reporting Strategies with Devin O’Herron and Jared Connors; and Responsible Minerals, Supply Chain and ESG, with Jared Connors and Daniel Zamora. Today, in our final post, we consider responsible minerals, supply chains and ESG.

We began with a review of the evolution on responsible mineral sourcing. It started with conflict minerals, which has been around for 10 years or so. This led to a rather dramatic shift in the worldwide corporate mindset and companies and stakeholders determined that there needed to be more engagement all levels within the supply change. Zamora pointed to the example of due diligence. “It began as a data collection exercise where you get transparency into your supply chain, but now it’s all about, what can you do  with that information after you collect data? What you see from the expectations of stakeholders is performing risk management, right to diligence activities within your supply chain.” This means going beyond regulatory requirements, it means risk management activities related to identifying sanctions within your supply chain.

One of the key themes of this series has been how a comprehensive ESG program can bring a much more integrated, holistic approach to not simply regulatory compliance but also in overall business operations. That also presents the opportunity to use an ESG approach to move from simply a reactive to proactive program. With Zamora, we look at steps a company can take to facilitate this change.

Zamora said, the “first step is you need to collect data efficiently. Once you do that officially, it allows your organization to have the resources in place to focus at how to perform risk management from within your supply chain. Number two, you need to have a specific program in place that would allow you to see and identify the risks so you can see where minerals are coming from and where the minerals are going afterwards. This allows you to identify those risks ahead of time, having risk assess verifiable sources out there that will allow determine who the bad actors are before then engage in bad behaviors.”

All of this allows a company to make better business decisions in terms of risk management. Zamora said, “it gives them time. It gives them a lot of power to take corrective actions, according to those risks. It could be communicating that those risks within their own supply chain. It could be passing that information along to their legal team. Once you have that ability to see these risks live as if an organization is being proactive about it instead of being reactive and waiting for those risks to show up in your supply change; a company will have a lot of power to have corrective action in order to mitigate those risks.”

We concluded with a discussion of the stakeholders who might be concerned with responsible minerals and how a corporation can use an overall ESG program to engage with them. This can include the shareholders, it could include customers, it could include employees, it could include third parties your organization does business with, and it could include the locales where a company does business or operates. Zamora said, “conversations have definitely changed,”. Now it has expanded to “even metal associations.” These conversations are also at “multiple levels within the supply chain. It is no longer the downstream companies and the shareholders right now, you see expectations at the mid-tier suppliers, you see these conversations at the smelters and at the upstream level.” All these levels are getting engaged in discussions and conversations around the ESG requirements.

To listen to the podcast this blog post is based upon, click here.

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Sunday Book Review

September 18, 2022 the Sports Cheating edition

In today’s edition of Sunday Book Review:

Run, Swim, Throw, Cheat: The science behind drugs in sport by Chris Cooper

Cheated: The UNC Scandal, the Education of Athletes, and the Future of Big-Time College Sports by Jay Smith

Cheating in E-Sports by Marcia Amidon Lusted

Intentional Balk: Baseball’s Thin Line Between Innovation and Cheating by Dan Levitt and Mark Armour

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Daily Compliance News

September 17, 2022 the Uber Cyberbreach Edition

In today’s edition of Daily Compliance News:

  • GOL Airlines settle FCPA claims for $41MM. (FCPABlog)
  • RR near strike is not about pay but scheduling. (NYT)
  • White House releases crypto regulation framework. (CryptoBriefing)
  • Uber was hit with a massive cyber breach. (WSJ)
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Corruption, Crime and Compliance

Episode 246 – NAVEX’s Global Hotline Benchmarking Report

As the leading hotline provider in the global market, NAVEX is uniquely positioned to collect and analyze employee reporting trends. Each year, NAVEX issues an important report on current trends in employee reporting, whistleblowers, internal investigations, and potential retaliation. NAVEX’s database consists of 1.37 million reports made in 2021 at organizations around the world. In this episode, Michael Volkov reviews the key findings from the 2022 report. Here is a link to the report. (https://www.navex.com/en-us/campaigns/2022-hotline-incident-management-benchmark-report/)

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Innovation in Compliance

Supply Chain and ESG – What You Need to Know: Episode 4 – Scope 3 Emissions Reporting Strategy with Devin O’Herron and Jared Connors

 

In part 4 of the Supply Chain and ESG – What You Need to Know series,Tom Fox is joined by Devin O’Herron and Jared Connors of Assent to discuss Scope 3 emissions reporting as the key to disclosure success. They talk about the importance of accounting for Scope 3 in your emissions strategy.

 

 

There are three scope levels within the emissions reporting strategy: Scope 1 refers to things like your vehicle or things you’re doing around your facility; Scope 2 is the purchased heat or electricity powering your facility; and Scope 3 is all those variables outside your four walls. The most important aspect of Scope 3 is purchased goods. This has a large impact on organizations that may not necessarily take in raw materials and directly manufacture those raw materials into a finished good. The supply chain is a very significant factor to consider when coming up with the emissions strategy as a company.

 

A recent study found that Scope 3 emissions are typically 11 times larger than an organization’s Scope 1 and 2 emissions combined. As mandatory climate disclosure legislation progresses into the future, the overall emissions strategy needs to start accounting for Scope 3 as much as possible. 

 

Resources

Assent

 

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Because That's What Heroes Do

WandaVision, Episode 6 – All New Halloween Spooktacular

In this podcast series, two complete MCU fans, Tom Fox, founder of the Compliance Podcast Network, and Megan Dougherty, co-founder of One Stone Creative, indulge in a passion for all things in the Marvel Cinematic Universe. We previously reviewed all the movies, and now we have a series on WandaVision. If you want to indulge in your love for the MCU with two fans passionate about all things MCU, this is the podcast series for you. For this offering, we continue with Episode 6 All New Halloween Spooktacular.

Some of the highlights include:

Ø The story synopsis.

Ø What are the key plot points?

Ø What were some of our favorite cookies?

Next up in our series WandaVision, Episode 7 Breaking the 4th Wall

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Daily Compliance News

September 16, 2022 the DOJ Brings Clarity Edition

In today’s edition of Daily Compliance News:

  • DOJ announces changes to enhance cooperation. (NYT)
  • Legalized pot spawned a wave of corruption in CA. (LATimes)
  • Can ‘the Merge’ save crypto? (NYT)
  • Can the company deny promotion to the bearded man? (WaPo)
Categories
Blog

Supply Chain and ESG – What You Need to Know: Scope 3 Emissions Reporting Strategy

I recently had the opportunity to visit with several folks from Assent Inc. for a sponsored podcast series entitled Supply Chain and ESG – What You Need to Know. We discussed: ESG drivers with Jared Connors and James Calder; UFLPA, Supply Chain and ESG with Travis Miller and Jamie Wallisch; the New World of Product Compliance and ESG, with Cally Edgren and Devin O’Herron; Emissions Reporting Strategies with Devin O’Herron and Jared Connors; and Responsible Minerals, Supply Chain and ESG, with Jared Connors and Daniel Zamora. Today, we consider a Scope 3 emissions reporting strategy.

We began with a discussion of the requirements for emissions reporting. There are three Scope levels within the emissions reporting strategy. Scope 1 and 2 are those emissions that are owned or controlled by a company, whereas Scope 3 emissions are a consequence of the activities of the company but occur from sources not owned or controlled by it. Connors provided some examples of each Scope, “Scope 1 is such things as your own vehicle fleets or things you are doing around your facility. Scope 2 is purchases such as heat or electricity for your facility, such as from your municipal power source. Scope 3 is all those variables outside your four walls.”

Connors went on to note, “This makes Scope 3 the most important of the three Scope emissions reporting, because it is so broad. It even includes things like employee travel. The most important aspect of Scope 3 is purchased goods, which has a very large impact on organizations that may not necessarily take in raw materials and directly manufacture from fabrication of those raw materials into a finished goods. Even if your organization designs products and influences those products, you typically will obtain your raw materials components through your supply chain. So purchased goods or supply chain is a very huge impact on the overall emission strategy for companies.”

O’Herron pointed to a recent Accenture study which estimated that Scope 3 emissions are typically 11 times larger than an organization’s Scope 1 and 2 emissions combined. With the increasing use of carbon taxes, and as they progress as a key tool, “the overall mission strategy frankly needs to start accounting for Scope 3.” But it is not simply risks but also opportunities, “because when it comes to Scope 3 emissions in particular, as we think about things like carbon taxes, risk in terms of risk, if you don’t understand what exactly that applies to your organization, you are missing a big opportunity.”

He further cautioned that while the conversation today is dominated by carbon, there may well be other minerals which fall under regulatory ambit. Moreover, there are other environmental factors at play, such waste management, recycled content in products, water usage. All of these additional costs that have not been traditionally quantified and accounted for when thinking about the product life cycle and design of the product. He stated, “when we are talking about Scope 3, in a broader context of just carbon, it’s about broadening the measure of impact burn closer to understanding and identifying the truthful cost of how we provision ourselves today.”

The bottom line is that organizations need to get a handle on their total emissions footprint, which includes what they are collecting from their suppliers upstream, their purchased goods or services, and those in Scope 3 emissions. You cannot manage what you do not measure. This means the “idea of diving into these details, has gained such relevancy and traction in the market.” It is providing a common language and identifying these common topics to focus on in terms of getting that information.

This is a big part of the overall strategy, the data collection at each level in the supply chain and how we may interact with our Tier 1 suppliers, but the disclosure that we get from them, there should be policies, procedures and programs around also creating transparency with their upstream suppliers. Connors concluded, “they have an element of pass down accountability as the phrase was coined so many years ago. I actually try to think of it as pass up accountability, because we are thinking about our supply chain upstream and what we need to collect from those organizations in order to meet the expectations of these regulatory pressures or these market disclosure requirements to create and promote transparency, not only in my operations, my four walls, but upstream of me as well.”

Please plan to join us tomorrow for our final post in this series, on responsible minerals, supply chain and ESG.

To listen to the podcast this blog post is based upon, click here.

Categories
Innovation in Compliance

Supply Chain and ESG – What You Need to Know: Episode 3 – The New World of Product Compliance and ESG with Cally Edgren and Devin O’Herron

 

In part 3 of the Supply Chain and ESG – What You Need to Know series, Cally Edgren and Devin O’Herron of Assent join Tom Fox to discuss product compliance and sustainability. They explore how the two worlds are starting to intersect. 

 

 

Making sure products meet regulatory requirements is what product compliance is all about. In recent years, the requirements have been changing. There used to be a focus on safety features like mechanical and electrical safety, but things changed with the RoHS Directive in 2002. That directive was meant to make sure electronic waste from third-world countries was safe. It was one of the first times a regulatory rule had more to do with sustainability than traditional product safety.

 

Manufacturers need to understand that their customers are no longer just concerned with what they hold in their hands at the end of the process – they want to make sure that their suppliers are using responsible processes. The two worlds of operations compliance and product compliance are starting to connect. As we become increasingly aware of the importance and relevance of the social and environmental costs associated with manufacturing processes and the barrier they present towards sustainability, ESG metrics represent another way of managing and measuring these externalities. 

 

Resources

Assent

 

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Career Can D0

To Belong and Be Respected with Ron Carucci

 

In this episode of Career Can Do, Mary Ann Faremouth chats with Ron Carucci, owner and Managing Partner of Navalent. A 2-time TEDx speaker, Ron works with CEOs and executives pursuing transformational change for their organizations. He is the bestselling author of nine books, the most recent one being selected by Bloomberg Businessweek as one of 2021’s Best Books. Ron explores how leaders can build purpose-driven companies of honesty and justice, and shares the importance of belonging.

 

 

To Be Honest: Lead with the Power of Truth, Justice and Purpose is the result of 15 years of research, Ron shares. The initial idea wasn’t a book, but a study on honesty and investigating the conditions under which people would act fairly, decently, and serve a greater purpose. The statistical models that came out of the research were so compelling, he wanted to share it.

 

The problem with generational differences is that we don’t see the conflict for what it is. Older and younger generations are fighting to be relevant and leave a legacy behind, and in that clash they misunderstand each other. They see each other as threats, when at the end of the day, we all want the same thing – to belong and to be respected. 

 

Resources

Faremouth.com