August 20, 2012
Dear Chairman Schapiro,
I am happy that the Securities and Exchange Commission is expected to issue final regulations concerning Section 1502 of the Dodd-Frank Act soon, and urge that these regulations be promulgated promptly. I want to be able to make a choice of whether or not to invest in businesses and products whose mineral sourcing practices contribute to the on-going crisis in the Democratic Republic of the Congo. All of the reporting requirements should take effect immediately. Prolonging the suffering of the people in the Congo would undermine what the law intended to accomplish.
All companies should be required to comply with the full set of reporting requirements as soon as they are published. Transparency in company supply chains is at the heart of this legislation. The SEC should provide specific instructions on what companies must do to check their supply chains to find out if they are sourcing conflict minerals that contribute to violence. In addition, the SEC should specify what companies must include in their reports on their country of origin inquiry and their due diligence on mineral sourcing. Companies that wish to label products as conflict-free should have to meet a high standard of proof, and the documentation of this claim should be easily available to the public. The rules should cover gold, tin, tungsten and tantalum, and all companies should be required to provide comprehensive reports, without exceptions.
Thank you for your work on this vitally important issue.