Conflict Mineral Compliance Intelligence

Audit every SEC filing.
Automatically.

COMPLY reads Form SD filings, extracts 13 compliance-critical fields, and scores every disclosure against deterministic governance rules — producing auditable decisions in seconds, not hours.

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Dataset
284
Filings
57
Companies
5yrs
History
11
Gov Rules
94%
Gap Rate
<$2
Per Filing
2021 – 2025
The Product

Governance in the loop.
Not after it.

Most compliance tools collect supplier surveys. COMPLY evaluates the actual public disclosure. Our LLM extraction layer reads the full narrative of every Form SD filing and outputs 13 structured compliance fields. A deterministic governance engine then checks every field against SEC Rule 17 CFR 240.13p-1 and OECD Due Diligence Guidance — producing an auditable, reproducible decision with full violation logs.

01

13-Field Structured Extraction

GPT-4o extracts RCOI approach, smelter disclosure, survey volume, surveyed spend, conformant SOR requirements, and more — validated by Pydantic schema on every run.

02

Deterministic Rule Engine

11 governance rules (GOV-16 through GOV-26) apply consistent, auditable logic. No probabilistic judgment. Every result is explainable, reproducible, and logged.

03

5-Year Trend Intelligence

ML-powered trajectory classification using linear regression. Classifies each company as IMPROVING, STABLE, DECLINING, or VOLATILE with 2026 forecast scores.

04

Vein AI Compliance Analyst

Ask natural language questions about any company's filing history, rule violations, or industry benchmarks. Powered by Claude with full portfolio context.

comply — audit RTX 2025
$ comply analyze RTX 2025
Fetching Form SD from SEC EDGAR...
Parsing with Azure Document Intelligence...
Running GPT-4o extraction...
Applying governance rules GOV-16 — GOV-26...
Extraction Result
company_nameRTX Corporation
segmentaerospace_defense
rcoi_approachrisk_based
surveys_sent1,340
surveyed_spend$11.0B
conformant_sorsrequired
Governance Result
GOV-22 Surveyed SpendPASS
GOV-23 Conformant SORPASS
GOV-25 RCOI ConductedPASS

Violations 0
Decision APPROVED

# Only filing in 284 to pass all 11 rules
The Pipeline

Raw PDF to audit decision
in seconds.

STAGE 01

Retrieve

Programmatic retrieval from SEC EDGAR by CIK. Supports HTML and PDF Form SD filings and attached Conflict Minerals Reports.

requests · SEC EDGAR API
STAGE 02

Parse

Converts mixed-format regulatory filings into clean structured text. Handles tables, narrative sections, exhibits, and appendices.

Azure Document Intelligence
STAGE 03

Extract

GPT-4o extracts 13 compliance fields as validated JSON. Pydantic schema ensures type-safe, reproducible outputs on every run.

GPT-4o · Pydantic validation
STAGE 04

Govern

11 deterministic rules check every field. No probabilistic judgment. Every pass and fail is auditable, explainable, and logged.

GOV-16 through GOV-26
Research Findings

What COMPLY found in
284 filings.

Real results from 57 U.S. public companies across aerospace, defense, automotive, electronics, medical, and industrial sectors — 2021 through 2025.

94%

Silent on Surveyed Spend

267 of 284 filings never disclose how much of their supply chain spend is covered by supplier surveys — making program breadth impossible to assess.

GOV-22 — Surveyed Spend Disclosed
56%

No Conformant SOR Requirement

Over half of companies do not require suppliers to source from RMAP-audited smelters — the single highest-value supply chain control under OECD guidance.

GOV-23 — Conformant SOR Requirement
3.5%

Fully Approved Rate

Only 10 of 284 filings passed all warning-level governance rules. RTX 2021 is the only filing in the entire dataset to pass all 11 rules.

Overall — Governance Decision Engine
6x

Survey Volume Disparity

Honeywell sends approximately 4,000 supplier surveys per year versus L3Harris at 669 — both in aerospace and defense. Same sector, dramatically different scale.

GOV-21 — Survey Volume Disclosed
$11B

RTX Surveyed Spend — 2021

RTX 2021 is the gold standard benchmark — the only filing to pass all 11 rules. Discloses $11B surveyed spend across 1,340 suppliers.

GOV-22 — Gold Standard Benchmark
100%

Risk-Based RCOI Adoption

All 57 companies use a risk-based Reasonable Country of Origin Inquiry approach — universal compliance with SEC best practice on this dimension.

GOV-17 — RCOI Approach Defined
Governance Engine

11 rules.
Zero ambiguity.

Every field extracted from every filing is checked against these rules. Critical rules trigger HIGH RISK. Warning rules trigger FLAGGED. Info rules are logged.

Rule Name Severity What It Checks
GOV-16Segment IdentifiedINFOCompany industry segment is identifiable for peer benchmarking.
GOV-17RCOI Approach DefinedWARNINGFiling describes a risk-based Reasonable Country of Origin Inquiry methodology.
GOV-18Supplier Selection — SpendINFOSupplier survey targeting is based on spend thresholds or criteria.
GOV-19Supplier Selection — 3TGWARNINGSelection criteria factor in the likelihood that suppliers use tin, tantalum, tungsten, or gold.
GOV-20Industry MembershipsINFOFiling references memberships in RMI, RBA, AIA, AIAG, OECD, or RMAP frameworks.
GOV-21Survey Volume DisclosedWARNINGNumber of supplier surveys distributed is disclosed. Silence may indicate no active program.
GOV-22Surveyed Spend DisclosedINFODollar value of supply chain spend covered by surveys is disclosed. Fires in 94% of filings.
GOV-23Conformant SOR RequirementWARNINGCompany explicitly requires suppliers to source from RMAP-conformant smelters and refiners.
GOV-24Continuous ImprovementWARNINGFiling describes specific improvement actions. Static programs indicate compliance stagnation.
GOV-25RCOI ConductedCRITICALCompany confirms it conducted an RCOI. Absence is a material violation of SEC Rule 13p-1.
GOV-26Survey Response RateWARNINGPercentage of supplier surveys returned is disclosed. Measures program effectiveness.
Pricing

Simple, transparent
pricing.

Start with a single analyst seat. Scale to enterprise-wide deployment with full corpus access and API integration.

Analyst
$199 / month

For individual compliance analysts and researchers reviewing company filings.

  • 1 user seat
  • Access to 284-filing dataset
  • Company deep-dive analysis
  • PDF audit report downloads
  • Vein AI analyst chat
  • 5-year trend history
Get Started
Enterprise
$1,499 / month

For audit firms, ESG agencies, and large organizations with complex portfolios.

  • Unlimited seats
  • All Team features
  • Full corpus — 1,200+ filers
  • REST API access
  • White-label reporting
  • Custom governance rules
  • Dedicated onboarding
  • SLA guarantee
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