By Mike Loch and Chris Bayer, PhD September 28, 2016 Many companies submitting conflict mineral disclosures to the SEC under Dodd-Frank Section 1502 failed basic plausibility tests concerning the Tin, Tantalum, Tungsten and Gold (3TG) Country of Origin (COO) and the 3TG Smelter or Refiner (SOR) countries in their annual reporting this year. As far as we know, no […]
I just returned home from an intense week of meetings in Paris associated with the 10th Forum on Responsible Mineral Supply Chains, co-organized by the ICGLR, OECD, and UN Group of Experts. With over 600 participants registered, this was the biggest ever meeting and significantly larger than the first forum held in December 2009 with […]
Earlier this month, the Securities and Exchange Commission (SEC) decided not to file further action in the ongoing lawsuit with U.S. manufacturers, effectively ending three years of legal action to define whether a company needed to disclose that their products were either “DRC conflict-free” or not found to be “DRC conflict-free” according to the implementing […]
I am honored to be recognized as #1 on the Top 100 Conflict Minerals Influential Leaders by Assent Global. This would not be possible without the help and support from many, some whom also are recognized leaders and I would like to thank everyone working on this important issue for their efforts. It does matter […]
There are cost and challenges to sourcing from conflict addected areas and implementing traceabilty and due diligence. Check out the open letter on Mineral Market Crisis from the ICGLR Secretariat.
This is the second in a two post series. First post here. Based on current SEC guidance, an Independent Private Sector Audit (IPSA) is needed if a company files a conflict minerals report and makes a “DRC Conflict Free” product declaration. The SEC Conflict Minerals Final Rule estimated the cost of an IPSA to be […]
There currently exists confusion on whether or not an independent private sector audit (IPSA) is required for large enterprises that submit a conflict minerals report for filing year 2015. The Conflict Minerals Final Rule as written by the Securities and Exchange Commission (SEC) is quite clear on when an IPSA is required[i] However, the confusion […]
September 15, 2015 Some people in life know exactly what they want to do from the moment they are born. For me, it has been more of a directionally correct journey with various course corrections along the way. But after over 25 years working on numerous issues of corporate social and environmental responsibility, I am […]
Here is a link to a well written, balanced and factual article. Congo’s Conflict Minerals: US Companies Struggle To Trace Tantalum, Tungsten, Tin, Gold In Their Products By Morgan Winsor @MorganWinsorIBT on September 18 2015 8:03 AM EDT