Many companies are now required by law to have a conflict minerals policy statement in place. This is due to the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502. This law requires companies to report their use of conflict minerals in their products.
Conflict minerals are those that are mined in the Democratic Republic of the Congo or in an adjoining country and that directly or indirectly finance armed conflict in the region. This can include minerals such as tin, tantalum, tungsten, and gold.
The purpose of a conflict minerals policy statement is to outline a company’s commitment to responsible sourcing of minerals and to demonstrate that it is not contributing to conflict in the Democratic Republic of the Congo or in an adjoining country.
What to Include in a Conflict Minerals Policy Statement
A conflict minerals policy statement should include at a minimum the following information:
* A statement of the company’s commitment to responsible sourcing of minerals
* A description of the company’s due diligence process
* A list of the smelters and refiners that the company uses
* A description of the company’s grievance mechanism
The company’s due diligence process should be designed to identify and mitigate the risk of conflict minerals being used in its products. This may involve working with suppliers to assess their supply chains and to develop conflict-free sourcing plans.
How to Implement a Conflict Minerals Policy
Once a conflict minerals policy statement has been developed, it is important to implement it effectively. This may involve training employees on the policy and developing systems to track the company’s use of minerals.
It is also important to engage with suppliers to ensure that they are also committed to responsible sourcing of minerals. This may involve working with suppliers to develop conflict-free sourcing plans.
Conclusion
A conflict minerals policy statement is an important tool for companies that want to demonstrate their commitment to responsible sourcing of minerals. By implementing a conflict minerals policy, companies can help to reduce the risk of conflict minerals being used in their products and can help to promote peace and stability in the Democratic Republic of the Congo and in the surrounding region.
There are many resources available to help companies develop and implement a conflict minerals policy statement. These resources include the Conflict-Free Sourcing Initiative website and the Organisation for Economic Co-operation and Development (OECD) website.
