developed markets such as North 
America or Europe might receive 
a low risk rating given that many 
of them will be subject to the 
same SEC rules. However private 
suppliers in emerging markets 
might be assessed at a higher risk 
and would be placed on notice that 
their statements are likely to be 
audited (if the governing contract 
permits) or asked to respond to a 
questionnaire about where they buy 
their minerals from.

9 

Online source : http://parl.gc.ca/HousePublications/Publication.aspx?Language=E&Mode=1&DocId=4668098

10 

The Great Lakes Region of Africa was defined in the bill to include Burundi, Rwanda, the Democratic Republic  
of Congo, Uganda, Kenya and Tanzania.

Conflict minerals 

and Canada

In September 2010, a private member 
bill with bi-partisan support was read 
in the House of Commons entitled 
the “Trade in Conflict Minerals Act”.

9

 

Had it passed, it would have pressured 
companies to practice due diligence 
on their supply chain of any minerals 
originating from the Great Lakes Region 
of Africa.

10

 The bill was tabled after 

the first reading and reintroduced in 
March 2013. Under the proposed bill, 

colloquially referred to as the “Canadian 
Conflict Minerals Rule”, a regulated 
company would be required to 
“exercise due diligence in respect of 
any extraction, processing, purchasing, 
trading in or use of designated minerals 
that it carries out in the course of its 
activities, or that it contracts to have 
carried out”. 

Joanne Lebert, director of the Great 
Lakes Program for Partnership Africa 
Canada (PAC) said in October 2012 
that Canada “hasn’t done enough” to 
support Canadian companies becoming 

© 2013 KPMG LLP, a Canadian limited liability partnership and a member firm of the KPMG network of independent member firms 
affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

6  |  At Risk  |  Volume 7, No. 1