March 9, 2017
Acting Chairman Piwowar:
As an interested person, I am pleased to submit comments regarding the U.S. SEC’s reconsideration of the Conflict Minerals Rule. I believe the rule has raised investor, enterprise and consumer awareness on the need for programs that assure legal and ethical sourcing. The legal and financial risk of irresponsible sourcing practices has put conflict minerals, cobalt and other materials such as cotton and palm oil as primary commodities with direct ties to human trafficking. and a number of other commodity traceability programs on the U.S. corporate agenda. The U.S. set the standard for this issue, which resulted in similar initiatives by U.S. states, the European Union and countries across the globe. Technology and improvements in tracing and verification are contributing to high success rates, better sourcing practices and for these reasons, I believe it would be a mistake to repeal or stay the Conflict Minerals 1502 requirements.
Respectfully submitted,
David H. Levine