more transparent and carrying out
their own due diligence concerning
conflict minerals.
11
Lebert discussed
her group’s efforts to create the
International Conference on Great Lakes
Region (“ICGLR”), a system whereby
a shipment of ore leaving the DRC
or Covered Countries would need an
export certificate proving the minerals
did not come from mines run by military
forces. Ottawa has, however, given
$1.7 million over the past two years to
PAC to help it implement the ICGLR and
an additional $3 million to stop conflict
minerals in the region.
Canadian
companies
Canadian entities using 3TG minerals in
their manufacturing process and exporting
their products to the United States or
selling their products to subsequent
exporters should consider whether the
minerals used in their products are conflict
free. By virtue of being tiered suppliers,
Canadian entities may find themselves
subject to scrutiny under the new Dodd-
Frank Act reporting provisions. If unable
to provide sufficient details to show
compliance, some of these entities may
suffer financially from lost contracts as
SEC registrants reconsider who their
supply partners will be going forward.
Proactive or
reactive? The
bottom line
Corporate executives should bear in mind
that conflict minerals may be the tip of the
regulatory iceberg. Companies may soon
have to be more transparent about their
supply chains with regard to a plethora of
local and national regulations, including
rules governing the use of slave labour,
environmental sustainability, and corrupt
practices as well as conflict minerals. A
proactive measure would be to adopt a
comprehensive approach to supply chain
compliance, rather than merely complying
with rules on conflict minerals. The initial
cost could be high, but the long-run
benefits are likely to be plentiful.
11
Online source: http://www.ipolitics.ca/2012/10/12/canada-not-preparing-for-new-rules-for-congolese-conflict-minerals-says-ngo/
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At Risk | Volume 7, No. 1 | 7