Statement at Securities and Exchange Commission Roundtable on Conflict Minerals
October 18, 2011
We believe that the entire supply chain must participate to develop effective tracking systems for conflict minerals. If certain issuers that use these minerals were exempted, that would prohibit both the development of such systems and also the flow of information required for investors to gain a full understanding of issuers’ exposures to these minerals.
We believe that reporting standards should be consistent with the statutory language of Section 1502 and should therefore apply disclosure rules equally to all stipulated conflict minerals—namely tin, tantalum, tungsten and gold. For example, gold has been a key contributor to conflict financing in the DRC. Therefore, in our view the provision of special conditions or exemptions for gold or any other mineral would weaken the intent of the disclosure rules. Greater transparency in the gold supply chain is critical to an investor’s ability to evaluate company sourcing practices in the DRC.
We believe that all companies across the value and supply chain should be covered by the rule—from “mine to product”—to ensure the greatest possible degree of transparency for investors and consumers alike. As investors, it is critical that we are able to assess standardized disclosures from all companies that may use these minerals in their products. (Read full statement.)