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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