February 6, 2017
Dear Chairman Piwowar,
Thank you for calling for comments with regard to the Conflict Mineral Implementation Rule. My name is Amanda Ulrich and since 2012 I have worked with city, state and federal government officials with regard to ways they can, through their own policies, support and strengthen Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). In Oregon, Portland in particular, we have given a priority to holding companies accountable for transparency in their supply chains, especially those which contain minerals sourced from Eastern Congo. As an active citizen it is important to me that local procurement policies take into account the transparency of supply chains with the companies with whom they do business. As a consumer, it is especially important to me that the electronic products I purchase contain minerals which are sourced from certified conflict free mines. The rule in question helps to make both of these goals reachable.
It is irrefutable that the strife and violence in Eastern Congo has been fueled over the control of the mineral wealth of the region for well over a decade, and that between 1998 to 2007 5.4 million have died as a result of armed conflict in Congo (International Rescue Committee). Violence and instability have continued since 2007, however there has not been an updated study since IRC completed their study in 2007, and so sadly the death toll is higher than the already horrific 5.4 million. Further, at least four of the minerals mined in Congo are used in electronic products used by consumers worldwide: Tin, Tungsten, Tantalum and Gold (three Ts and Gold). As a consumer of these products, I feel its important to recognize our inadvertent connection to where and how these minerals are sourced.
In recognition of our connection to the use of electronic products which contain the 3 Ts and Gold, in 2010 the Conflict Mineral Reporting rule was included in Section 1502 of Dodd-Frank. The rule simply requires all publicly traded companies report if anywhere in their supply chain minerals sourced from Congo can be found. It does not require a boycott, nor does it require punishment. Consumers, such as myself, have a right to know where the components which make up the products we buy are sourced from.
Since the implementation of the Conflict Minerals Rule, we have seen the market value of minerals sourced from conflict mines decrease, thereby making the trade of these minerals less lucrative for armed groups and stabilizing formerly unstable mines and thereby promoting stability for local Congolese. Further, in 2016 the International Peace Information Service (IPIS) found that:
Three out of the four conflict minerals have largely become peaceful, as 79 percent of miners at tin, tantalum, and tungsten mines surveyed in Congo now work at conflict-free mines. This is a major change, as the U.N. stated in 2010 that "almost every mining deposit was controlled by a military group.
The number of internally displaced people has decreased from 3.4 million in 2008 to 1.9 million at the end of 2016.
( Conflict-Free Sourcing Initiative, Conflict-Free Smelter Program Indicators, available at http://www.conflictfreesourcing.org/members/active-and-compliant-smelter-count/ (last accessed December 5, 2016).
Since 2010, we have seen the infrastructure required for companies to audit their supply chains develop and prosper. Companies such as Intel have remained committed to sourcing from the region, not to mention other companies which partner with nonprofit organizations such as The Enough Project and Eastern Congo Initiative to support local Congolese through farming of cocoa and coffee beans. The Conflict Mineral Rule is but one piece of the puzzle to help bring sustained peace to Congo, and its an important piece which must be built upon, not taken down.
As a consumer, I will continue to support companies who are committed to transparent supply chains and investment in regions such as Congo. In a global economy consumer and source will always be connected, and companies have a due diligence to know where the materials in their supply chains originate.