(33) Amnesty International concludes that companies along this supply chain are not conducting adequate human rights due diligence and are failing to implement due diligence processes that go beyond 3TG
, as recommended by the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance), established in 2011.
Nevison notes that, while the EU and Canadian proposals target the same 3TG
materials, Canada appears to be looking beyond the large SEC-regulated companies that the Americans have covered for rules that will apply to all firms, irrespective of their size and including component makers.
The SEC rule compels corporate disclosures around whether any of the 3TG
materials used in a company's products originated in any of the covered countries, and if so, whether these conflict materials are "conflict free" or not.
Annual, Public Disclosure: Companies must disclose if any of the 3TG
conflict minerals in its products originated in the Congo or adjacent commies.
SEC-registered companies must determine if they have any exposure to 3TG
* First, SEC-registered companies must determine if they have any exposure to 3TG
The metals and ores currently I classified as conflict minerals are tin, tantalum, tungsten, and gold; these metals are also collectively referred to as "3TG
." This requirement affects most electronics, aerospace, communication, automotive, jewelry, healthcare devices, and industrial I machinery.
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