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In the fifth consecutive year of analyzing companies’ conflict minerals compliance and reporting, and in a time marked by uncertainty regarding the future of the conflict minerals rule, RSN’s research unveils different strategies used by companies and industries. The comparison between 2017 and 2018 scores regrettably shows a decline in due diligence efforts of a large number of companies. This likely follows an indication by the Security and Exchange Commission’s Division of Corporation Finance that it would not recommend enforcement action for failure to comply with the requirements of Section 1502 of the Dodd-Frank Act.

However, the actions of a few leading companies, pursuing constant improvement of their monitoring efforts and due diligence practices, illustrate the value and necessity for increased attention to human rights abuses in global supply chains. The uncertainty brought by the Trump administration and its rejection of regulatory frameworks in every sector is crucial when analyzing companies’ limited efforts to improve the quality of their disclosures. In this anti-regulation climate, leading companies’ risk mitigation practices are highlighted and stand out from the crowd.

 
 

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As You Sow

As You Sow is a nonprofit organization dedicated to increasing environmental and social corporate responsibility. Founded in 1992, As You Sow envisions a safe, just, and sustainable world in which environmental health and human rights are central to corporate decision making. Its Energy, Environmental Health, Waste, and Human Rights programs create positive, industry-wide change through corporate dialogue, shareholder advocacy, coalition building, and innovative legal strategies. For more information, visit www.asyousow.org.

 
 

Responsible Minerals Initiative

Founded in 2008, the Responsible Minerals Initiative serves as a collaborative, multi-industry platform that encourages and improves regulatory compliance and company due diligence through the development and broad application of tools and resources in mineral supply chains. More than 360 companies from over 10 industries participate in the Responsible Minerals Initiative (RMI) to support responsible sourcing of minerals globally. The RMI offers the Responsible Mineral Assurance Process smelter audit program (3TG + Cobalt), Minerals Reporting Templates (3TG + Cobalt), Risk Readiness Assessment (15 minerals/31 issue areas), Due Diligence Guidance, and ongoing stakeholder engagement. RMI envisions a future in which businesses can contribute positively to the fostering of peace and stability through their sourcing decisions. For more information, visit www.responsiblemineralsinitiative.org