Why Engage?
In the past, the conflict minerals law (Dodd-Frank Act) forced automotive companies to comply with the regulatory requirements for 3TG.
Publicly traded U.S. companies have been required since 2010 to report annually to the U.S. Securities and Exchange Commission (SEC) whether the products that they manufacture or contract to manufacture contain "conflict minerals," i.e., anything which contains tantalum, tin, tungsten, and gold. These minerals are used in numerous automotive components with various applications. This requirement is intended to increase supply chain transparency of minerals sourced from the Democratic Republic of the Congo, adjoining countries, and other high-risk regions shown to fund armed groups violating human rights. The U.S. legislation requires companies to conduct due diligence to verify the information they report in accordance with a “recognized international framework,” i.e., the Organization for Economic Cooperation & Development (OECD) Due Diligence Process. Recent European Union and Chinese regulatory actions reinforce these expectations. The EU legislation expanded the scope of conflict mineral reporting to all global conflict afflicted high-risk areas (CAHRAs), which is voluntary for downstream companies currently, but could become mandatory as soon as 2023. While these broader materials are not currently legislated directly, responsible sourcing of raw materials has gained the attention of media, external stakeholders, and auto companies themselves, and both the U.S. and E.U. regulations include provisions for expanded material reporting as deemed necessary.
Today, many automotive OEM companies have expanded their scope and established responsible sourcing requirements for other minerals. It has now become essential for all automotive companies to develop responsible sourcing policies for their supply chain, in order to conduct business in the automotive industry.
Contact Us For Group Information: Corporate Responsibility Team