A recent, independent evaluation of the public company “conflict mineral” filings submitted to the SEC for reporting year 2014 under Dodd-Frank Section 1502 found that of the 1,262 companies evaluated, 312 scored a perfect 100% and 245 scored below 75% in meeting the requirements of the SEC rule.
The most noticeable shortcoming was that more than half of the filers did not disclose country or countries of origin of the conflict minerals in their products). Almost half of the filers did not disclose the facilities used to process the necessary 3TG.
The study evaluated the filers’ conflict minerals disclosures against two sets of criteria: those established by the SEC rule and a non-binding “good practice” metric developed by the Responsible Sourcing Network (RSN), a human rights organization and Sustainalytics, a research firm specializing in environmental, social and governance analysis. While the majority of filers met most of the regulatory requirements, most scored significantly lower on the “good practice” measures.
The study was designed and executed by Chris N. Bayer, Ph.D., with the assistance of a broad advisory panel comprised of Fern Abrams of IPC, Lawrence Heim of Elm Sustainability Partners, Michael Littenberg of Schulte, Roth & Zabel, Charles Riepenhoff, Jr. of KPMG and Jonathan Hughes of Assent Compliance.
IPC members interested in learning more about the study are invited to attend a free webinar by Dr. Bayer on September 15.