"Conflict Minerals" -- Dodd-Frank Section 1502
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.
Our contributions to the issue of conflict minerals include:
Filing Status RY2017
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:
3TG+C Smelter and Refiner Disclosure Conformance
with Leading Due Diligence and Assurance Standards
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:
-> view the report's raw data
Issuer Evaluation (RY2016)
DI assessed all 1,153 issuers' filings in our RY2016 benchmarking study, its 3rd such assessment:
-> click here to download the report;
-> click here to order company scorecard(s);
-> the resource Filing Examples and Scoring Explanations (RY2015
IPSA Analysis Presentation
-> here a presentation on IPSA analysis approaches delivered to a U.S.
Letter to Acting SEC Chairman Piwowar
-> here DI’s letter in response to Acting SEC Chairman Piwowar's January 31,
2017 statement and request for comments.
Issuer Evaluation (RY2015)
For Reporting Year 2015 as well, we conducted an evaluation of the SEC compliance and OECD conformance of issuer's conflict minerals disclosures:
-> version 3 of the report, released on November 15, 2016, is 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.
Issuer Evaluation (RY2014)
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:
-> here version 2 of our report, published Nov. 16, 2015;
-> here the scorecards of all issuers containing the detailed compliance scores.
2015 Supply-Chain Survey
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:
-> here the video of the presentation delivered Nov 5, 2015 in Stuttgart.
We spearheaded a survey ("Dodd-Frank Section 1502: Post-Filing Survey 2014") estimating the actual cost of Dodd-Frank Section 1502 to issuers.
Cost Projection White Paper