The popular online source for sustainable news and resources related to business, GreenBiz.com, is featuring a four-part series of articles on compliance with the U.S. Securities and Exchange Commission (SEC) rule Section 1502. The SEC recently voted to adopt Section 1502, a controversial rule which is a provision of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act. The rule requires manufacturers to trace their supply chains and disclose whether or not the tin, tantalum, tungsten, or gold used in their products come from the Democratic Republic of Congo (DRC) or an adjoining country. These minerals are referred to as “conflict minerals” because militant groups within DRC use violence (rape and other gender based violence, as well as murder and other atrocities) to control miners within that country, which include women and children. The purchase of conflict minerals from DRC funds a war between the government and rebel militias over control of the country’s mines. Controlling those mines means power because those minerals are used within virtually all electronic products that we use in today’s world. What makes the rule controversial is what some groups have called a “loophole” that allows companies to declare the source of these minerals as indeterminable; flexibility is also allowed on scrap and recycled minerals. For more information on the recent SEC vote and the controversy, see the GreenBiz article “SEC’s conflict minerals vote comes under fire.” For more information on conflict minerals in general, see the previous SEI blog post entitled “Every action has an equal and opposite reaction,” as well as the Raise Hope for Congo web site. Read the text of the final rule (Section 1502) here.
The first article in the GreenBiz series was published on 8/30/12 and is entitled “Full disclosure: How SEC’s conflict mineral rule could affect you.” It was written by Patricia Jurewicz, the Director for the Responsible Sourcing Network (RSN). RSN is a project of As You Sow, a nongovernmental organization that “promotes environmental and social corporate responsibility through shareholder advocacy, coalition building, and innovative legal strategies.” This article discusses what companies will have to report on and how, discusses room for interpretation of the SEC rules, and provides a list of products (not just electronics) that contain conflict minerals.
The latest article in the series, also by Patricia Jurewicz, is entitled “Tackling tungsten, tin: Choosing tools for conflict mineral reports.” This article discusses systems and tools used to facilitate the reporting process in compliance with Section 1502. Included at the end of the article are links to possible software solutions that manufacturers may wish to explore to help track their supply chain.