Executive Summary
Profits from conflict minerals found in the Democratic Republic of the Congo (DRC) have supported conflict, human rights violations and labour and environmental abuses in the region for years. Companies that use these minerals in the design and manufacture of their products and components – called “downstream” companies – are concerned about these abuses, and are taking action to avoid contributing to conflict in any way.

Working in cooperation, Downstream Companies have developed a variety of policies and processes to better understand the origin of these conflict minerals to facilitate responsible decision-making about sourcing. Companies’ actions alone cannot ensure security, improve governance or bring about peace in the region. However, by finding shared solutions to common challenges in sourcing, companies can ensure they have as positive an impact as possible on the people and communities associated with minerals.

This paper is intended as a practical guide for Downstream Companies that have reporting obligations about conflict minerals that may be used in their supply chains. This paper may also be helpful for suppliers to better understand their customers’ expectations and requirements. This paper is not a set of rules or a method for compliance with existing legislation. Rather, this paper seeks to provide clear explanations and practical tips for companies on how to understand the source of minerals in their supply chains and how that understanding can contribute to their required reporting.

Currently, three major bodies of work address conflict minerals reporting: the United States Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act); the related United States Securities and Exchange Commission Final Rule on compliance with Dodd-Frank (SEC Final Rule); and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). This paper gives examples of how a downstream company may use the OECD Guidance to meet its SEC compliance and reporting requirements by correlating the OECD Guidance steps to the SEC compliance steps needed to meet U.S. reporting requirements.

Due to the fact that companies’ current conflict minerals reporting obligations are solely related to DRC conflict minerals, as defined in the Dodd-Frank Act, this paper focuses exclusively on DRC conflict minerals. Although the OECD Guidance applies to minerals from any conflict-affected or high-risk area, references in this paper to “conflict-free” should be understood as DRC conflict-free, which means the material does not directly or indirectly finance or benefit armed groups in the DRC.

5 Practical Steps to Support SEC Conflict Minerals Disclosure - White Paper Version 2.0 (2015) DOWNLOAD

post

page

attachment

revision

nav_menu_item

custom_css

customize_changeset

oembed_cache

user_request

wp_block

wp_template

wp_template_part

wp_global_styles

wp_navigation

wp_font_family

wp_font_face

acf-taxonomy

acf-post-type

acf-field-group

acf-field

ai1ec_event

exactmetrics_note

Anti-Human Trafficking Authentication Criteria Company-level and Site-Level
Guidance

The following criteria can be used by any organization to help it design an effective and transparent system for preventing human trafficking in its operations and those of its supply chain. It can also be used by an organization or an independent t...Read More

TAGS: Global
Footsteps Forward Investors Against Slavery and Trafficking Asia Pacific Annual Report 2021–2022
Guidance

The authors are a group of investors working to help end modern slavery, which currently affects an estimated 40 million people globally, with 70% of that number estimated to be in the Asia-Pacific region. IAST APAC was established in 2020, based on...Read More

TAGS: Asia
Trafficking in Human Beings and Terrorism: Where and How They Intersect
Guidance

Since trafficking in human beings continues to evolve, with criminals employing ever more sophisticated, a multi-disciplinary approach to combat trafficking is not only recommended but necessary. In recent years, several reports have emerged alludin...Read More

TAGS: Global
Modern Slavery and Organised Immigration Crime Programme: Annual Report 2021-22
GuidanceGood Practices

The Modern Slavery and Organised Immigration Crime Programme continues to build on the work undertaken in previous years. In 2021-22 the programme continued to drive improvements in the identification of victims and improve Modern Slavery criminal j...Read More

TAGS: Europe