Conflict Minerals

DI associates Ava Leipzig and David Park author a case study comparing the SEC compliance and OECD conformance of 12 companies in the telecommunication industry. They find wide disparaties in the quality of due diligence and corresponding disclosure among the companies under study: while they are all publicly-traded US issuers, only five of them had ever filed a Form SD. And among these filers, only two satisfied SEC filing requirements as well as largely aligned with the OECD's due diligence standard.    

Under the direction of Luca Maiotti, Benjamin Katz, Hannah Koep-Andrieu and Tyler Gillard (OECD Centre for Responsible Business Conduct), it was an honor for DI, along with the Canadian NGO IMPACT, to author the OECD's Monitoring & Evaluation Framework on the implementation of the OECD's minerals Due Diligence Guidance (DDG). This Framework will help understand to what extent corporate due diligence implementation is impacting mineral supply chains and the conditions in producer countries suffering from conflict.    

Having analyzed the disclosure performance of 370 Smelters or Refiners (SORs) pursuant to leading assurance standards and the OECD Due Diligence Guidance, we are now pleased to share our findings.

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• Report (v.2)

• Report's scorecards:

  • English

  • Mandarin

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DI reviewed the issuer filings pursuant to the law and rule, and observed an overall filing drop of 222 conflict minerals disclosures – 16.8% in total – between RY2013 and RY2017.  

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• Report

Here is a presentation on IPSA analysis approaches delivered to a U.S. government agency.

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• IPSA analysis presentation

DI assessed all 1,153 issuers' filings in our RY2016 benchmarking study, its 3rd such assessment. 

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• Report

• raw data

DI’s letter in response to Acting SEC Chairman Piwowar's January 31, 2017 statement and request for comments.

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• Letter

For Reporting Year 2015 as well, we conducted an evaluation of the SEC compliance and OECD conformance of issuer's conflict minerals disclosure.

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• Version 3 of the report "Dodd-Frank Section 1502: RY2015 Filing Evaluation", released on November 15, 2016, available here

• The scorecards of the 1,220 issuers assessed are available here

• Here the presentation that DI delivered at the 2016 CFSI Annual Conference

• Here our raw data

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We conducted a compliance evaluation ("Dodd-Frank Section 1502: RY2014 Filing Evaluation") of the conflict minerals disclosure filings of 1,271 issuers for Reporting Year 2014.

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• Report v.2, published Nov. 16, 2015

• The scorecards of all issuers containing the detailed compliance scores

• Raw data

We ran a supply chain survey ("Dodd-Frank Section 1502: Supply-Chain Survey 2015") to unravel the nuts and bolts of conflict minerals program implementation along 3TG supply chains.

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• The ppt of findings

We spearheaded a survey ("Dodd-Frank Section 1502: Post-Filing Survey 2014") estimating the actual cost of Dodd-Frank Section 1502 to issuers.

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Tucked away in the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 is a disclosure law targeting four raw materials that originate from the DRC (Congo).  
Section 1502 of the law requires public companies (issuers) to report the origin of the so-called “conflict minerals” – tin, tungsten, tantalum, and gold – contained in their products.
In October 2011 we developed an economic cost model projecting the economic cost of the SEC's Proposed Rule that was largely adopted in its Final Rule​.