March 19, 2017
Dear Chairman Piwowar,
Thank you for calling for comments with regard to the current status of the Conflict Minerals Implementation Rule.
I represent Sabin Metal Corporation, one of the world's largest private refiners of platinum-group metals. Our business is oriented almost entirely on recovery of platinum group metals from petroleum and pharmaceutical-based catalysts from major petrochemical and pharmaceutical companies. We do not source from mines, nor countries in high-risk areas per OECD guidelines, but rather established multinational petroleum refineries and pharmaceutical manufacturers.
We fully support the goals of the Conflict Mineral rules, as well as the OECD guidelines on supply chain transparency they implement. However, any gold we refine comes from secondary, primarily US sources, incidental to the catalyst we refine. It is not worth the expense per ounce in either dollar cost, manpower, or confidentiality risk to our proprietary refining processes to undergo a third party audit for the small amounts of gold we do refine. (We do not handle tin, tantalum or tungsten.)
As a private company we are not required to file disclosure reports re conflict minerals to the SEC under Dodd-Frank, and this is causing confusion among many of our industry peers who wish to understand our position better.
We fully support the goals of eliminating any source of conflict. As a compliance professional however I can say that as the rules are drafted - for those companies that do source from the Congo region, they will do more harm than good because many companies will simply avoid the risk of doing business with that region altogether than expend the additional due diligence efforts required.
Sabin Metal Corporation has endorsed and implemented the OECD's Model Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High Risk Areas.
We thank you for your time and consideration of our concerns, and hope that future implementations of the Conflict Minerals rules are better suited for the wider varieties of metal refining and recycling operations that occur in the United States.
Sincerely,
Marc Pane, Esq.
Corporate Counsel
Sabin Metal Corporation