At the end of May, issues were raised regarding conflict minerals by publicly traded companies in the United States. Indeed, conflict minerals are involved in the supply chain of these companies. The problems with the minerals were alerted to in filings with the Securities and Exchange Commission (SEC).
In 2017, the SEC decided not to enforce Section 1502 of the Dodd-Frank Act and not to pursue actions against companies for failure to comply with the requirements of that section.
This has caused a lot of outrage, especially by NGOs. For example, the NGO Responsible Sourcing Network (RSN) stated that the SEC's decision has "fundamentally destroyed interest in conflict minerals�.
The International Tin Supply Chain Initiative (ITSCI) is a due diligence program responsible for the reliability of chains of custody for conflict minerals
However, the NGO Global Witness has announced that reliance on the ITSCI should be reduced because the scheme would allow "laundering of contaminated minerals�. The NGO published a report "The ITSCI laundromat: How due diligence scheme looks to launder conflict minerals�. In this report, the NGO states that the scheme appeared to "minimize or ignore incidents that seriously compromise its supply chain.
In 2010, the Dodd-Frank Act required U.S.-listed companies sourcing conflict minerals to conduct due diligence. The objective was to avoid contributing to the financing of human rights violations or armed conflicts. Allowing the links between conflict zones and the illegal mining operations that fuel them to be cut. The goal was to provide responsible sourcing for industries.
The EU has introduced a similar regulation, effective January 2021, available in the EU Official Journal (OJ). Thus, importers, smelters and refiners of tungsten, tin, tantalum and gold (3TG) must conduct due diligence checks when annual import volumes exceed set thresholds (available in the OJ).
It is possible to find these minerals in the production of everyday objects/products (e.g.: aeronautical products, electronics, toys, etc.).
As a result, the regulation requires companies to make procurement decisions based on the risks disclosed by their suppliers.
The regulation affects you if you are:
The areas of conflict are:
In 2015, the European Parliament had shared a brief communicating the definitions of conflict minerals:
EcoMundo's experts help you manage the traceability of hazardous substances in your supply chain by liaising with your suppliers to identify the possible presence of SVHC or other regulated substances in their references.
In particular through its SVHC Factory software, which allows you to parameterize and monitor in real time the information collection process throughout your supply chain and to store your traceability information on a single platform.
For more information, do not hesitate to contact Christian Freneuil or one of our experts !
At the end of May, issues were raised regarding conflict minerals by publicly traded companies in the United States. Indeed, conflict minerals are involved in the supply chain of these companies. The problems with the minerals were alerted to in filings with the Securities and Exchange Commission (SEC).
In 2017, the SEC decided not to enforce Section 1502 of the Dodd-Frank Act and not to pursue actions against companies for failure to comply with the requirements of that section.
This has caused a lot of outrage, especially by NGOs. For example, the NGO Responsible Sourcing Network (RSN) stated that the SEC's decision has "fundamentally destroyed interest in conflict minerals�.
The International Tin Supply Chain Initiative (ITSCI) is a due diligence program responsible for the reliability of chains of custody for conflict minerals
However, the NGO Global Witness has announced that reliance on the ITSCI should be reduced because the scheme would allow "laundering of contaminated minerals�. The NGO published a report "The ITSCI laundromat: How due diligence scheme looks to launder conflict minerals�. In this report, the NGO states that the scheme appeared to "minimize or ignore incidents that seriously compromise its supply chain.
In 2010, the Dodd-Frank Act required U.S.-listed companies sourcing conflict minerals to conduct due diligence. The objective was to avoid contributing to the financing of human rights violations or armed conflicts. Allowing the links between conflict zones and the illegal mining operations that fuel them to be cut. The goal was to provide responsible sourcing for industries.
The EU has introduced a similar regulation, effective January 2021, available in the EU Official Journal (OJ). Thus, importers, smelters and refiners of tungsten, tin, tantalum and gold (3TG) must conduct due diligence checks when annual import volumes exceed set thresholds (available in the OJ).
It is possible to find these minerals in the production of everyday objects/products (e.g.: aeronautical products, electronics, toys, etc.).
As a result, the regulation requires companies to make procurement decisions based on the risks disclosed by their suppliers.
The regulation affects you if you are:
The areas of conflict are:
In 2015, the European Parliament had shared a brief communicating the definitions of conflict minerals:
EcoMundo's experts help you manage the traceability of hazardous substances in your supply chain by liaising with your suppliers to identify the possible presence of SVHC or other regulated substances in their references.
In particular through its SVHC Factory software, which allows you to parameterize and monitor in real time the information collection process throughout your supply chain and to store your traceability information on a single platform.
For more information, do not hesitate to contact Christian Freneuil or one of our experts !