February 21, 2017
I am well aware of the horror that exists today in the DRC region and I support US government efforts to improve a situation in any part of the world experiencing similar mayhem. However DF1502 is simply not an effective way to drive any meaningful change.
For the past four years, I have managed the conflict minerals compliance initiative for a Global Tier 1 automotive company. My company is publicly traded and as such, falls under the reporting requirements of DF1502. We manufacture heavy metal components which contain very small amounts of 3tg. In addition, we are many levels removed from the actual smelters or refiners in our supply chain. Despite our efforts to develop and execute a robust process to obtain smelter information, I believe that we have failed to accurately identify the actual smelters involved in the products we sell. In the end, we are completely reliant on the efforts of our entire supply chain to investigate and report on their sources of 3tg and I have little confidence that they have done so with the required level of due diligence to be factually accurate.
I strongly suggest that the SEC immediately discontinue enforcement of DF1502. Should the law be suspended or repealed, any replacement should emulate the recent EU legislation which focuses on the smelters and direct importers of 3tg and not on the downstream companies like mine who are simply wasting valuable resources chasing their tail.
Fred Mrachina
Supplier Risk and Trade Compliance Manager