DODD -FRANK LEGISLATION

Witness and fellow campaign organisation CCFD-Terre Solidaire have called for legislation similar to that in the US. The reality is that if the EU doesnt make the OECD recommendations compulsory, many companies wont do the checks, thereby undercutting the rms that do try to do the right thing, said Global Witness campaigner Annie Dunnebacke. But the SECs delay is not a reason for companies to remain idle. Many rms, most notably those in the electronics sector, have been collaborating for some time to tackle the issue and put due diligence programmes in place. Companies can follow OECD due diligence standards and they can map supply chains and a lot of companies are doing that, understanding their supply chains to the processing facility level or the smelter level where they source from, says Hall. The OECD guidance contains a ve-step due diligence framework for organisations to follow for responsible sourcing. These steps are: establishing strong company management systems; identifying and assessing risks in the supply chain; designing and implementing a strategy to respond to identied risks; carrying out independent third-party audits of supply chain due diligence at identied points in the supply chain; and finally, public reporting on supply chain die diligence. In addition to the framework, the guidelines also make clear the type of behaviour that should not be tolerated and the measures that can be taken for risk mitigation over issues such as supply chain security or misrepresentation of the origin of minerals and how to resolve these. It also highlights a number of red ags, such as if the minerals originate in a high-risk area or if suppliers have a track record of sourcing from the region, that should trigger due diligence. The OECD code of conduct even has advantages over Dodd-Frank, says Rick Goss, vice president, environment and sustainability at the Information Technology Industry Council (ITI), one of the industry bodies collaborating on this. The OECD guidance adopts a wellregarded approach, a company at a dierent point in the supply chain has a dierent set
32 CPO AGENDA | SPRING 2012

THE 3TG METALS AND THEIR MINERALS

Tantalum (obtained from tantalite, columbite or coltan) A strong conductor of both heat and electricity, tantalums primary use is in capacitors found in electronic products, such as computers, mobile phones and other consumer electronics. It also produces good alloys and is resistant to acids, giving it use in the aerospace and automotive industries. Tungsten (obtained from wolframite) Tungsten has the highest melting point of any metal, which makes it ideal as the lament in lightbulbs. Its strength also means compounds are used to create cutters for saws, drills and other tools. This characteristic also makes it popular in the creation of hard alloys used in industries such as defence. Because it has a high density, it is also used as ballast in racing cars. Tin (obtained from cassiterite) Tins low melting point means it is often used as a solder in the manufacture of circuit boards, or to join pipes. A low toxicity permits its most obvious use as a plating for cans to preserve food. Tin as a cause of conict is not a new phenomenon. Access to tin deposits was one of the reasons that prompted the Roman invasion of Britain. Gold While the jewellery industry is the major consumer of gold around 60 per cent the electronics sector also uses the metal for wiring and coating because it is an excellent conductor. According to the World Gold Council, only 166,600 tonnes of gold have been mined since the beginning of civilisation.

of responsibilities. It tries to identify reasonable eorts that each separate pocket in the supply chain should take. This is far dierent from 1502, which put the full legal responsibility on the end-user, he says. The other difference is the OECD approach allows for remedial action to be taken. If you as a company determine there has been a violation in the supply chain, it invites and encourages you to work with that supplier to remediate the issue. 1502 doesnt have that type of provision the

way it is written you are responsible for funding conict, or you are not. There is not the chance to say yes we have this due diligence system in place, we identied an instance of non-compliance, but were still good guys because we took these steps. Much of the technology sectors work to tackle the problem has focused on the metal tantalum, as this is where the sector has the most buying power. Collaboration between industry bodies and member companies has led to the establishment of
www.cpoagenda.com

Frank Dodds.2.sr.indd 32

20/3/12 08:39:42