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ITRI letter to SEC Acting Chairman Piwowar March 2017

Posted by: Jeremy Pearce
17th Mar 2017
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ITRI letter to SEC Acting Chairman Piwowar March 2017

Comments on January 31, 2017, statement on the Commission's Conflict Minerals Rule

Acting Chairman of the SEC, Michael S. Piwowar made a statement on 31st January 2017 regarding ‘Reconsideration of Conflict Minerals Rule Implementation’ https://www.sec.gov/news/statement/reconsideration-of-conflict-minerals-rule-implementation.html

ITRI has provided comments to this statement as attached, and in summary;

• While a de-facto embargo did occur on 3T’s in some areas of DRC and the adjoining countries, after six years of hard work by stakeholders to ensure the availability of credible supply chain traceability and important risk information via the iTSCi programme, there is no longer any widespread embargo;

• All legitimate mineral businesses both in Africa and around the world will incur some costs associated with their responsibilities to avoid human rights abuses and conflict financing, however, there is no evidence to suggest that this cost has put operators out of business. From data on iTSCi membership it would appear the opposite is true as the less legitimate operators are those now less likely to remain in the 3T supply chain;

• Through the evaluation of iTSCi incidents detailed data is available on the extent of armed group control and human rights abuses in the 3T sector, as well as on a range of other important risks. This data shows the low level of serious human rights and conflict issues around iTSCi monitored areas, and also shows that many positive outcomes on improved security, governance and responsible company actions have been achieved;

• The vast majority of interests in the 3T sector, are, and have always been local or foreign interests with a long history of association with the region. There is no evidence of any increase in any ‘less benign’ interests in the mineral trade, while there is evidence on the increasing engagement of US based companies;

• While Section 1502 of Dodd Frank was not well conceived and did create significant harm, the situation in the 3T sector has overcome these various hurdles and is now on a positive trend. On balance, repeal of the Rule would now have further negative, rather than positive effects. 

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