Mining the Disclosures 2014

An Investor Guide to Conflict Minerals Reporting

Indicators Shortlist

A study from Responsible Sourcing Network and research provider Sustainalytics measuring company performance on a major human rights risk found mixed results.

In last year’s inaugural round of filings, 1,315 companies submitted conflict minerals disclosures as required by Section 1502 of the 2010 Dodd Frank Act. Mining the Disclosures: An Investor Guide to Conflict Minerals Reporting provides a transparent and scalable methodology for analyzing company social performance as part of an integrated approach toward environmental, social, and governance reporting.

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Reporting Findings

Companies in the IT sector, which has borne the brunt of activist concern over conflict minerals, led the pack — Intel, Qualcomm, and Apple were all top performers. Companies in lagging industries like Energy Equipment, Containers and Packaging, and Healthcare Equipment scored much lower.

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We applaud the authors of this report for digging deeper into the topic of conflict minerals reporting. We share their view that you cannot have true accountability without transparency.
- Jackie Sturm, VP, Global Supply Management for Intel Corporation

Read our full statement

The report calls on investors to encourage lagging industries to engage in conflict-free certification schemes and take a more proactive approach to due diligence. While some companies took the initiative to provide robust conflict minerals reports, too many took the easy way out by fulfilling only the most minimal compliance requirements. As companies see their peers adopting leading practices, we expect more transparency and greater depth in conflict minerals reporting.

The study examined a pilot pool of 51 companies across 17 industries with high exposure to conflict minerals. The methodology was designed to encourage higher quality reporting, incentivize companies to support multi-stakeholder efforts, and set a precedent for comparing social performance.

Conflict minerals reporting is a central part of the strategy adopted by stakeholders across sectors and continents to help free the minerals trade in the Democratic Republic of Congo and the broader Great Lakes region of Africa from the grip of armed groups.

Qualcomm is proud to be recognized as a leader in the effort to ensure industry supply chains aren’t supporting groups that commit human rights violations in the Democratic Republic of the Congo or adjoining countries. But this is not a single company or industry effort – cross-industry collaboration, engagement with non-industry stakeholders and support for projects on the ground are critical to our effort to promote the responsible sourcing of raw materials.
- Roawen Chen, Senior Vice President of Operations at Qualcomm Technologies, Inc.

Reporting Resources

Our Reporting Resources include the full list of 18 indicators with their elective answers, which form the foundation of our research methodology. We are also offering Step-by-Step Guidance for Companies and Investors, in an easily-accessible bulleted format.

Conflict Minerals Guidance for Companies and Investors
Excerpt from Mining the Disclosures, offering step-by-step guides for companies and investors

Indicators Shortlist
General overview of how companies can fulfill stakeholders’ disclosure expectations

Indicators Longlist
The full list of 18 indicators with their elective answers, forming the foundation for our research methodology