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/

© 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.

At Risk  |  Volume 7, No. 1  |  7