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Conflict Minerals
"Conflict minerals" is a term that designates minerals that may have benefited armed groups or organized crime. Such groups, in turn, are associated with various adverse impacts such as extortion, child labour, forced labour, and sexual violence. Dodd-Frank Section 1502 and the SEC Final Rule was the first legislative effort prescribing mandatory corporate due diligence on the four (4) designated conflict minerals (tin, tungsten, tantalum and gold). The OECD's Due Diligence Guidance concerning minerals is the to date internationally-recognized due diligence framework.
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Apart from offering scorecards to companies who wish to have their public SEC filings assessed, our contributions to the issue of conflict minerals include the following.
Latest Research
M&E Framework for OECD's DDG
(2021)
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.
3TG+C Smelter and Refiner Disclosure Conformance
with Leading Due Diligence and Assurance Standards
(2018)
Filing Status RY2017
(2018)
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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IPSA Analysis Presentation
(2017)
Here is a presentation on IPSA analysis approaches delivered to a U.S. government agency.
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Letter to Acting SEC Chairman Piwowar
(2017)
DI’s letter in response to Acting SEC Chairman Piwowar's January 31, 2017 statement and request for comments.
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Issuer Evaluation RY2015
(2016)
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
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The scorecards of the 1,220 issuers assessed are available here
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Here the presentation that DI delivered at the 2016 CFSI Annual Conference
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Issuer Evaluation RY2014
(2015)
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
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The scorecards of all issuers containing the detailed compliance scores
Supply-Chain Survey
(2015)
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
Issuer Survey
(2014)
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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Cost Projection White Paper
(2011)
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​.