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Enough Project Comment to the SEC in Support of Conflict Minerals Rule Implementation

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Enough Project Comment to the SEC in Support of Conflict Minerals Rule Implementation

Posted by Enough Team on February 27, 2017

On January 31, Acting Chairman of the Securities and Exchange Commission (SEC) Michael Piwowar welcomed interested parties to submit comments in response to a statement calling into question the current Conflict Minerals Rule. In the weeks following, numerous companies, investors, activists, NGOs, and others have come out publicly in support of the Rule.

The Enough Project opposes any suspension, weakening, or repeal of the current Conflict Minerals Rule, and urges the SEC to increase enforcement of the Rule. Our full comment can be found here.



Mr. Michael S. Piwowar

Acting Chairman

United States Securities and Exchange Commission

100 F Street NE

Washington, DC 20549

Re: Comments on Reconsideration of Conflict Minerals Rule Implementation

The Enough Project submits this comment in response to Commissioner Piwowar’s January 31, 2017 Statement on the US Securities and Exchange Commission’s (“the Commission”) Conflict Minerals Rule (“the Rule”). Significant evidence has shown that the Rule has had an overall positive impact in eastern Democratic Republic of Congo (“Congo”) and on minimizing supply chain risks to U.S. corporations and investors, increasingly so over time as implementation of the Rule has improved. We thus urge the Commission to leave the current Rule intact and to take additional measures to ensure compliance with the Rule before pursuing changes. The Rule is consistent with other standards on corporate supply chain due diligence, such that change to or repeal of the Rule will not reduce costs for U.S. businesses.

Suspending or significantly weakening the Rule would undermine peace and security and would not reduce costs for U.S. businesses. The Rule has led to improvements in the rule of law in the mining sectors of Congo, Rwanda, and other Great Lakes countries, contributed to improvements in humanitarian conditions in Congo and a weakening of key insurgent groups, and resulted in tangible benefits for U.S. corporations and their supply chains. If the Rule is suspended or weakened, it would incentivize armed groups in eastern Congo to return to hundreds of mines, causing an increased humanitarian crisis. This would also lead to increased corruption in the minerals certification process in Congo and the region, thus creating major risks for U.S. companies sourcing minerals, and it would likely lead to a new de facto embargo on minerals from Congo, Rwanda, and the Great Lakes region. Furthermore, the cost for U.S. businesses to comply with the rule has been 74 to 85 percent less than the original SEC estimate, according to new information from Elm Sustainability Partners…

Continuing reading Enough's comment here.



Additional Information:

  • Read excerpts from some civil society letters here.

  • Read Enough's status update on the implementation of the conflict minerals law, "Progress and Challenges on Conflict Minerals: Facts on Dodd-Frank 1502," here.