Two years after its initial rankings, activists Enough! have issued their updated rankings on electronics companies’ progress on conflict minerals. Even CNN picked up this up and reported it on the front page of CNN.com. A quick review of the summary report indicates that Enough appears to have addressed some of the points from our critical review of the initial 2010 rankings. However, our comments concerning the three flawed questions remain substantially valid. Although we have not yet analyzed the detailed responses behind the summary report (those responses are available here), we plan to do so soon. Similarly as we look even further ahead, we anticipate updating our own report on the financial impact of Enough’s rankings.
Read more →Based on our ongoing dialogs with clients and other companies, and our attendance at last week’s EICC-GeSI Conflict Minerals Workshop in Philadelphia, we have a few predictions about the upcoming second report on OECD’s downstream pilot program on the implementation of their due diligence guidance. The report was originally scheduled for release last month, but is not yet available and we don’t know when it will be published (although we would expect in advance of the next meeting the first week of May). As our client base consists more of heavy industry, hard metals and non-electronics consumer products, some of our predictions stand in contrast to “conventional wisdom.” Especially for US companies subject to DF1502, there is an increasing recognition that the makeup of the downstream pilot participants is heavily skewed toward the electronics industry, and the results of the pilot are therefore not representative of heavy manufacturing or other non-electronics sectors. At the same time, we expect an increased awareness of conflict minerals (CM) issues in pilot participants which means a related increase in uptake of basic program elements such as company policies on conflict minerals. Many companies (arguably most companies (a) outside the electronics industry and (b) not
Read more →Elm welcomes Michele Bruelhart as a guest blogger. Michele is the Global Traceability Manager with UL-STR in Burundi and attended the EICC-GeSI Workshop held in Brussels recently. She provided Elm with her perspective on the meeting, and regional progress on … Continue reading →
Elm attended this week’s EICC Extractives Supply Chain Workshop VI on conflict minerals, where approximately 200 attendees were present from industry associations, manufacturers from a range of industries, retailers, law firms, the OECD and representatives of several Central African organizations in the minerals trade. It is Elm’s opinion that a clear rift exists between policy development/governmental organizations and the companies who are expected to implement conflict minerals traceability programs. Elm observed the following points being voiced most frequently in open discussions with panelists and in “hallway discussions” between attendees: Governmental and quasi-governmental organizations are almost universally pointing to the recently finalized OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas and the Supplement on Tin, Tantalum and Tungsten as THE answer to all traceability program needs. In contrast, many of the US companies present who have attempted to apply the Guidance consider the document unusable and unrealistic. The most common complaints: a major lack of actionable, specific implementation steps/detail and the uncertainty about how the Guidance will comply with SEC requirements. Similarly, a confusing array of new standards, initiatives, policies and documents are emerging from a range of industry groups, non-governmental and quasi-governmental
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