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The United Nations has declared that companies or individuals who buy minerals from Congo must ensure they are not helping illegal armed groups in order to avoid violating international sanctions. A U.S. law requires that any organization that must file with the Securities Exchange Commission take due diligence to ensure that any minerals purchased from Congo were properly sourced. No comment yet.
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Based on discussions held at the briefing, it was apparent that regardless of any potential conflict minerals regulatory (Dodd-Frank 1502) changes, the need for supply chain transparency is not going away. However, this desire for improved corporate social responsibility will not come without challenges. As new regulations emerge around the globe – including conflict minerals reporting in the European Union, and consumer and investor demands grow louder, the temptation increases for some within the vast supply chain to hide or manipulate information. So, compliance work is quickly becoming a part of comprehensive ethical sourcing programs.
EcoVadis's insight:
Supply chain transparency is progressing at a rapid pace same as government regulations; are you ensuring transparency in your supply chain?
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As discussed in a previous post, the SEC's final Conflict Minerals rule, adopted in August 2012 to implement Section 1502 of the Dodd-Frank Act, has a number of undefined terms and ambiguous provisions that require difficult interpretations of the rule's applicability. One example is whether the critical term "product" includes packaging.
EcoVadis's insight:
The Conflict Minerals rule still contains some shadow areas and further guidance is needed to cope with this highly complex issue. When?
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The European Union (EU) will begin discussions on whether to develop a conflict minerals-type regulation during a December 5, 2012 internal workshop. DG Trade is leading this effort and has request input from industry, academia, and non-governmental organizations (NGOs)....
EcoVadis's insight:
As a ripple effect of the Conflict Minerals Act of 2009 passed in the U.S., possible regulations are likely to have significant impacts for European companies in terms of supply chain disclosure and accountability, due-diligence mechanisms. |
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When it comes to conflict minerals and federal reporting requirements, suppliers and their customers are increasingly recognizing that the breadth and scope of their compliance efforts extend far beyond simply meeting the terms of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
EcoVadis's insight:
Companies, even if they are not a publicly traded company, need to follow the same SEC rule for conflict minerals disclosure. Small or large companies that are providing services to the federal government need to source responsibly; are you engaging your company to follow those rules?
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More than 50 sustainable, socially responsible, and faith-based investment groups representing $458.67 billion in assets under management released a statement today expressing their support for the SEC’s final rule for Conflict Mineral Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
EcoVadis's insight:
Last October, U.S. business group led by the National Association of Manufacturers launched a lawsuit against the S.E.C. complaining the conflict mineral law is costly to administer and ineffective. This week, investors managing $458.67 billion worth in assets responded to the lawsuit.
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Global gold authority and industry body the World Gold Council (WGC) is pleased with the industry’s reception of its Conflict-Free Gold Standard (CFGS), which has been welcomed by various stakeholders – including WGC member companies...
EcoVadis's insight:
We know the Conflict-free Gold Standard was released by the World Gold Council in October 2012. Of interest here is the current development of third party audit schemes and external-assurance services to ensure conformance with the standards in 2013. |
New bill requiring administration to review procurement policies