RSN, the Multi-Stakeholder Group, Socially Responsible Investors, and the Securities and Exchange Commission (SEC)

Over the past two years, RSN was involved with submitting a number of comments to the SEC on behalf of the multi-stakeholder group (MSG), a group of socially responsible investors, and industry-wide initiatives designed to put an end to conflict minerals.

MSG Submissions to the SEC

Responsible Sourcing Network organized an unlikely coalition of Fortune 500 companies, investors, and human rights groups into a multi-stakeholder group (MSG) that submitted five joint letters to the SEC recommending an appropriate amount of transparency and accountability in mineral supply chains.

MSG - November 2010

http://www.sourcingnetwork.org/storage/FINAL_Multi-stakeholder_SEC_Recommendations_for_Conflict_Minerals.pdf

MSG – March 2011

http://www.sec.gov/comments/s7-40-10/s74010-152.pdf

MSG – August 2011

http://www.sec.gov/comments/s7-40-10/s74010-302.pdf

MSG – November 2011

http://www.sec.gov/comments/s7-40-10/s74010-410.pdf 

MSG - August 22, 2012

http://www.sec.gov/comments/s7-40-10/s74010-585.pdf

MSG Statement Regarding 1502 Lawsuit

Following the petition for judicial review of the final rule implementing Section 1502 filed by the National Association of Manufacturers, the US Chamber of Commerce, and the Business Roundtable, the MSG urges all stakeholders to continue the important work underway to address the critical issue of transparency in the supply chains for these minerals.

http://www.sourcingnetwork.org/blog/2012/11/20/msg-statement-on-the-challenge-to-conflict-minerals-rule.html

SRI Submissions to the SEC

Signed by 49 socially responsible investors (SRI) each, shareholders made detailed recommendations to the SEC regarding how companies should file their Conflict Minerals Reports and which companies should file.

SRI - November 2010

http://www.sec.gov/comments/df-title-xv/specialized-disclosures/specializeddisclosures-54.htm

SRI - March 2011

http://www.sec.gov/comments/s7-40-10/s74010-158.pdf

A Subset of Investors Submission

February 1, 2012

Another Letter to the SEC Highlighting the Most Important Components Investors Are Looking for in Section 1502

http://www.sec.gov/comments/s7-40-10/s74010-475.pdf

Submission by Patricia Jurewicz, Director of Responsible Sourcing Network 

October 18, 2011

Since the SEC will not acknowledge efforts that are not formally submitted to the SEC, this letter references the variety of industry-led and multi-stakeholder initiatives created to promote conflict-free minerals from the DRC. It highlights the PPA, EICC-GeSI Conflict-Free Smelter (CFS) Program, EICC-GeSI Reporting Template and Dashboard, International Conference on the Great Lakes Region (ICGLR) Certification Mechanism, BGR (agency of the German government), and Certified Trading Chains (CTC) Pilot Project in Rwanda.

http://www.sec.gov/comments/s7-40-10/s74010-335.pdf

Roundtable on Conflict Minerals

Oct 18, 2011

http://www.sec.gov/news/otherwebcasts/2011/conflictmineralsroundtable101811.shtml