Conflict Minerals


"Conflict minerals" is a term that designates minerals that in some shape or form have benefited armed groups or organized crime. Such groups, in turn, are associated with various adverse impacts as per the OECD's Due Diligence Guidance concerning minerals

Our contributions to the issue of conflict minerals include:


M&E Framework for OECD's DDG

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.    

ME front.JPG


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:  

->    download report

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:

->    download report (v.2)

->    view the report's raw data

->    download the report's scorecards -- in English or Mandarin)


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

RY2016) discusses specific cases assessed;

IPSA Analysis Presentation

->    here a presentation on IPSA analysis approaches delivered to a U.S.                

       government agency.

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 ppt of findings;

->    here the video of the presentation delivered Nov 5, 2015 in Stuttgart.


Issuer Survey

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 


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.