Subject: File No.
From: Stephen G Price, Ph.D.
Affiliation: Justice and Peace Liaison, Society of African Missions

March 6, 2017

Dear Commissioner Piwowar,

I ask that the Conflict Minerals Rule not be rescinded or weakened but rather implemented. As an associate of a missionary group having long experience in Africa, I am convinced that efforts to hinder the unregulated use of minerals from conflict areas are worthwhile in human lives saved and suffering alleviated. The "conflict diamonds" campaign did a great deal of good twenty years ago, and it is right to apply similar efforts for transparency to other "conflict minerals". It is true that care must be taken not to deprive legitimate "artisinal miners" of livelihood, and local populations of the benefit of their own resources, but the chaotic and violent situation in D.R. Congo and indeed in the Great Lakes region make that situation unusual. U.S. consumers are very interested in purchasing products which they can be confident are not produced at the cost of promoting violence. The best way to have that assurance is for open information to be available about and from the companies buying resources from the source. The SEC rule is an effort toward that. It has already had an effect on hindering armed conflicts funded by mineral extraction. It is very possible to maintain such a restriction without destroying a legitimate industry. See the very recent news about Apple Corporation and its efforts to source cobalt in a responsible way without permanently shutting down a local industry. The position of some corporations that "if we do not get free access to minerals, the Chinese (or others) will do so" is not moral or economically beneficial in the long run, because it furthers the existence and proliferation of violent groups and of vicious labor practices. The Conflict Minerals Rule is a valuable tool for promoting peace in a region that has suffered decades of turmoil and suffering. The least we can do is maintain implementation of this Rule.

I appeal to you to keep the Conflict Minerals Rule and to implement it fully.