March 6, 2017
I want to add my voice of support for continued implementation of the Conflict Minerals Rule.
It is my understanding that there has been steady progress since 2013, in decreasing violence and enhancing the rule of law in the mining sectors of Congo, Rwanda, and other Great Lakes countries. Consequently there have been measurable improvements in humanitarian conditions in Congo and a weakening of key insurgent groups, along with resultant tangible benefits for U.S. corporations and their supply chains. The U.N. stated in 2010, the year that Dodd-Frank became law, that nearly every mine in the Kivu provinces was controlled by a military group, but according to an October 2016 study by the International Peace Information Service, 79 percent of miners at tin, tantalum, and tungsten mines surveyed in Congo now work at conflict-free mines. Clearly the problem is not fully resolved, but the noted progress under the Rule is compelling.
If the Rule is suspended or weakened, it would incentivize armed groups in eastern Congo to return to hundreds of tin, tantalum, and tungsten mines, causing an increased humanitarian crisis. This would also lead to increased corruption in the minerals certification process in Congo and the region, thus creating major risks for U.S. companies sourcing minerals, and it would likely lead to a new de facto embargo on minerals from Congo, Rwanda, and the Great Lakes region. Furthermore, the cost for U.S. businesses to comply with the rule has been 74 to 85 percent less than the original SEC estimate, according to new information from Elm Sustainability Partners.
As a consumer, I want to curb complicity in supporting violence in the DRC and I believe the data support a beneficial trend in transparency and stability with the Rule in place.
I urge you to keep the Conflict Minerals Rule fully intact, and to work with your fellow SEC commissioners to enforce the Rule moving forward.
Thank you for your consideration.