corporate rankings 2012

8/9/2019 Corporate Rankings 2012

1/17

Taking Conflict Outof Consumer Gadgets

Company Rankings on Conflict Minerals 2012

Sasha Lezhnev and Alex Hellmuth August 2012

WWW.ENOUGHPROJECT.ORG


2/17

Taking Conflict Outof Consumer GadgetsCompany Rankings on Conflict Minerals 2012

Sasha Lezhnev and Alexandra Hellmuth August 2012

ON THE COVER: Tin ore from Walikale, the minerals

capital of eastern Congo. February 2012.

SASHA LEZHNEV/ENOUGH PROJECT


3/17

1 The Enough Project • w ww.enoughproject.org | Takin g Confl ict Out of Cons umer Gadgets

Introduction and summary

Leading elecronics companies are making progress in eliminaing conflic minerals

rom heir supply chains, bu sill canno label heir producs as being conflic ree. Since

Enough’s las corporae rankings repor on conflic minerals in December 2010, a major-

iy o leading consumer elecronics companies have moved ahead in addressing con-flic minerals in heir supply chainsspurred by he conflic minerals provision in he

Dodd-Frank Wall Sree Reorm and Consumer Proecion Ac and growing consumer

acivism, paricularly on college campuses. Mos firms have improved heir scores rom

he 2010 rankings, bu some laggards sill remain.

In paricular, our leading companiesInel, Moorola Soluions, HP, and Apple

have been pioneers o progress. Tese firms have moved orward o develop soluions

despie delays in he legislaive rule-making process by he U.S. Securiies and Exchange

Commission, or SECan excuse ha many oher companies have used o explain heir

lack o significan acion. Tese leading companies have developed conflic miner-als programs ha have paved he way or oher companies o ollow. Tese include a

smeler audiing program and an aid projec or lagging smelers, direc sourcing and

aid projecs o help Congo develop a clean minerals rade, and racing projecs o dig

deeply ino heir supply chains o ideniy precise numbers o smelers. Several oher

companiesSanDisk, Philips, Sony, Panasonic, RIM, and AMD, in paricularhave

significanly improved heir effors by surveying heir suppliers, piloing due diligence,

and joining he smeler audi program.

A he oher end o he specrum, laggards are also sanding ou due o lack o progress

and communicaion. For example, despie growing public awareness abou his issue

and significan indusry movemen, Ninendo has made no known effor o race or

audi is supply chain. Sharp, HC, Nikon, and Canon are aking iniial seps o join

indusry effors, bu heir progress remains ar behind indusry leaders. Addiionally,

oher indusries ha use conflic mineralsauomoive, jewelry, mining, and indusrial

machineryare finally aking iniial seps o ackle he problem because o he legisla-

ion, bu remain ar behind he consumer elecronics firms.


4/17


Areas of progress:

Te majoriy o elecronics companies surveyed have made progress in hree main areas.

• Tracing: Mos major elecronics companies have raced urher along heir supply

chains o find he sources o heir minerals. Saring wih Apple, seven firms have now

publicly idenified he number o smelers involved in heir supply chains and nearly

all consumer elecronics companies are underaking similar mapping projecs.

• Auditing: Many more smelers are now being audied by hird-pary audiors hrough

he indusrywide Conflic-Free Smeler, or CFS, program. weny smelers have

already passed he audis, including he majoriy o analum smelers and wo

Chinese smelers.1

• Certification: A group o companies is saring o help Congo develop a clean minerals

rade ha helps communiies. Seven end-user companies are sourcing rom conflic-

ree mines in Congo, and 16 elecronics companies have joined he Public Privae

Motorola Mobility 35

0 10% 20% 30% 40% 50% 60%

Intel

HP

SanDisk

AMD

RIM

Acer

Dell

Microsoft

Nokia

Panasonic

IBM

Sony

LG

Samsung

Toshiba

LenovoCanon

Nikon

Sharp

HTC

Nintendo

Percentage of progress toward responsible sourcing on conflict minerals

60

54

48

44

42

40

40

38

35

33

27

27

27

21

178

8

8

4

0

27

Companies 30% and over

Companies between 10 and 30%

Companies 10% and below

*Lighter shaded/striped area represents

2010 score, if available.

70%

24*

32

4

14

13

15

15

19

5

5

6

7

2

Philips 4811

Apple 3813

Electronics companies ranked by progress on conflict minerals


5/17


Alliance or Responsible Minerals rade, or PPA. Te PPA is a parnership creaed

by he U.S. governmen, NGOs, and corporae parners o suppor he developmen

o a clean-minerals supply chain rom Congo and he surrounding region. Moorola

Soluions, Inel, and HP also helped ge he smeler-audi program o accep conflic-

ree minerals rom Congo and he region ha are cerified by a regional governmen

body. Tis means ha greaer amouns o clean minerals rom Congo will go ino

elecronics producs nex year as mines begin o be cerified.

Tese seps have had an effec on he ongoing conflic in Congo, as armed groups are

currenly only able o generae approximaely 35 percen o wha hey made rom he

rade in in, analum, and ungsen, or 3 s, wo years ago.2 Conflic in, a rade suscep-

ible o il legal smuggling hrough Rwanda and previously worh over $115 million per

year o armed groups, has become increasingly difficul o sell due o audis ha now

recognize he physical differences beween Congo’s and Rwanda’s inmaking he

Congolese maerial difficul o relabel as Rwandan.3

Despie his progress, gold smuggling remains a major problem and he new Rwandan- backed M23 rebel group is creaing insabiliy. Bu ech company acion has been a he

cener o he long-erm progress in creaing soluions wihin mineral supply chains, as

he elecronics audi program only acceps minerals ha are ully raced back o heir

mines o origin and are conflic-ree, i.e. excluding conflic minerals.

While companies engaged in finding soluions should be recognized or heir effors, here

are sill significan gaps where improvemen in conflic mineral policies can be made.

Five main gaps:

• Ensuring that “conflict free” is not Congo free: Companies ha use he 3 s and gold

in heir producs should srive o inves in a way ha creaes shared value or boh

companies and communiies. A handul o companies are helping Congo develop

a clean rade, bu some companies are aking a hands-off approach o insruc heir

suppliers o no buy minerals rom Congo and he region. Tis approach helps cu off

armed groups bu leaves mining communiies in Congo behind. In order o accom-

plish boh goals, more firms should join he Public-Privae Alliance, or PPA, inves in

projecs o source clean minerals ha help communiies in easern Congo where i is

sae o do so, and suppor livelihood projecs o help mining communiies.

• Buying from conflict-free smelters: For smeler audis o have a meaningul impac,

companies should require heir suppliers o only purchase rom conflic-ree smelers.

Oherwise, smelers will have litle incenive o source responsibly. Four companies

have pu such requiremens in place bu have no begun enorcing hem. For example,

Apple saes is policy in is annual code o conduc: “As he EICC/GeSI iniiaive


6/17


[Elecronic Indusry Ciizenship Coaliion’s conflic-ree smeler audi program] com-

plees smeler audis in analum, in, ungsen, and gold, we will require our suppliers

o source rom hese conflic-ree cerified smelers.” Oher companies should adop

similar policies and begin enorcing hese policies hrough audis o heir firs-ier and

oher suppliers o only source rom conflic-ree smelers. Tere are enough conflic-

ree analum smelers o now begin enorcemen on analum. By proacively puting

in place a policy on his subjec and enorcing i, companies can help speed up heaudi process and incenivize smelers o ake par in and pass he audis.

• Getting all the smelters audited: Wihin he las 18 monhs, he conflic-ree smeler

audi program has cerified 12 analum, wo in, and six gold smelers as conflic ree.

o dae, no ungsen smelers have been designaed conflic ree. In 2012 Inel, HP,

and GE pu ogeher a program o help smelers cover audi coss, bu more effor

is needed. ech companies and oher indusry cusomers should do more oureach

direcly o smelers.

•

Getting other industries more involved: Mos companies ouside he large consumerelecronics indusryjewelry, auomakers, aerospace, and indusrial machineryare

no playing nearly as much o a role in he siuaion. Tis is par o he reason or low

smeler paricipaion in audiing programs. In order o incenivize more smelers o

paricipae in he audis, more o heir cusomers need o be involved, paricularly

rom hese oher indusries. Companies rom he jewelry, auomoive, indusrial

machinery, and aerospace indusries should join he CFS audi program, he PPA,

and begin direc conflic-ree sourcing programs similar o Soluions or Hope o help

Congo develop a clean minerals rade.

•

Making certification a process that civil society and governments participate in: Te conflic-ree audi program is sill mainly run by indusry despie he posiive

sep o adding one independen exper ono is oversigh commitee. In line wih

oher cerificaion regimes like he Fair Labor Associaion or he Exracive Indusries

ransparency Iniiaive, he audi program should be governed by a join board made

up o indusry, civil sociey, and governmens. EICC-GeSI should amend he CFS

audi review commitee o have ull and equal mulisakeholder paricipaion, similar

o he PPA governance board. Expanding conrol beyond indusry would preven

he program rom being hamsrung by rules ha do no allow he publicaion o he

names o ailed smelers or compeiive indusry reasons.


7/17


Outstanding company efforts:

wo companies surveyed sood ou ahead o he pack in heir exraordinary leadership.

• Intel was he firs company o publicly commi o making a ully conflic-ree produc

wihin a deadlinea conflic-ree microprocessing chip by 2013. I has aken several

oher major seps under he leadership o Chie Operaing Officer Brian Krzanich.Inel chairs he review commitee or he smeler audi program, co-chairs he indusry

associaion work group on conflic minerals, has visied 50 smelers, co-ounded a

program wih HP and GE o pay or smeler audis, and has visied easern Congo o

beter undersand how he company can have a posiive impac.

• HP has been acive a muliple levels. When enough smelers are available i will

require is suppliers o use only audied, conflic-ree smelers. HP also co-ounded

he smelers incenive program. HP has been acive by helping Congo develop a clean

minerals rade, serving on he governance commitee o he PPA, purchasing minerals

rom Congo, raveling o easern Congo o see local sysems firshand, and being hemos acive corporae paricipan in a diplomacy work group on Congo. I also signed

ono he mulisakeholder group on srong SEC regulaions.

Several oher companies deserve special menion or noable acions on conflic minerals:

• Apple was he firs company o publicly ideniy he number o smelers in is sup-

ply chain175and require is suppliers o use only audied, conflic-ree smelers,

when enough are available. I also leads a smeler raining program.

•

AMD, maker o compuer chips, has been a leading public policy voice on conflicminerals. AMD esified a he SEC’s roundable on he rules or he conflic minerals

provision in he Dodd-Frank law, co-chairs he mulisakeholder group on he SEC

rules, and published aricles calling or more governmen acion on conflic minerals.

• Sony led a parnership o ge Japanese elecronics companies more involved on con-

flic minerals, shepherding a process ha led Japan’s ech associaion o sign a memo-

randum o undersanding, or MOU, wih he U.S.-based EICC o paricipae in he

smeler audi program.

• Toshiba, Apple, HP, and Nok ia pu new policies in place o require all o heir suppliers

o use only audied, conflic-ree smelers, once enough are available.

• Nokia, Panasonic, Philips, AMD, HP, and Microsoft are piloing inernaionally agreed-

upon due diligence guidance on conflic minerals in line wih he Organizaion or

Economic Co-operaion and Developmen, or OECD, due diligence model.

Intel

0

10%

20%

30%

40%

2012 2010

50%

60%

70%

+36%

HP

0

10%

20%

30%

40%

2012 2010

50%

60%

70%

+22%


8/17


• SanDisk is he mos improved company, being he firs company o publish he names

o is smelers and begin audis o is suppliers ha cover conflic minerals.

• Acer, Intel, LG, Panasonic, and Philips also publicly idenified he number o smelers

in heir supply chains, helping ransparency.

• Microsoft, GE, Panasonic, and Motorola Solutions sood up and issued saemensagains a lawsui ha he U.S. Chamber o Commerce, a powerul indusry lobby

group, had hreaened agains he SEC on is regulaions or he Dodd-Frank law on

conflic minerals. Te lawsui could effecively overurn he law.

• Motorola Solutions , no ranked in our survey because o is decreased size ollowing a

company spli, has been very acive in helping Congo develop a clean minerals rade,

co-chairing he indusry working group on conflic minerals, pioneering he Soluions

or Hope projec, and advocaing or sronger governmen acion.

•

AMD, Nokia, AT&T, Dell, RIM (Blackberry), GE, Sony, Sprint, HP, Telefonica, Intel,Toshiba, Verizon, and Motorola Solutions are helping Congo develop a clean minerals

rade by joining he Public Privae Alliance on Responsible Minerals.

• Motorola Mobility, HP, Intel, Motorola Solutions, Nokia, RIM (Blackberry), and Bosch

joined he Soluions or Hope program o develop a clean minerals rade in Congo.

Componen manuacurer AVX deserves credi or seting up his program, and com-

ponen maker Kemet has se up a similar program in Kaanga.

• IBM helped raceabiliy in Congo and Rwanda by donaing a daabase and raining or

he Congo-Rwanda racing sysem called iSCi.

Other industries: Starting work but lagging behind overall

I companies rom oher indusries ha use conflic minerals were o be surveyed and

ranked using our crieria, he majoriy would likely earn ew o zero poins. Enough only

ranked large consumer elecronics companies because o our exensive engagemen wih

hem over he pas hree years and a basis on which o differeniae heir acions. Bu he

involvemen o oher indusries is also imporan and here has been nascen engage-

men wih he larges companies in six oher key secors: auomoive, aerospace, jewelry,

mining, indusrial machinery, and reail.

Wih a ew excepions, responses rom mos companies in hese oher key indusries

have hus ar been epid. Tere are several ousanding issues ha mus be addressed o

more effecively handle he conflic-mineral issue. Based on he passage o he Dodd-

Frank legislaion, companies and associaions in some o hese secors have begun o


9/17


ake seps o eliminae conflic minerals rom heir supply chains. However, many o he

companies are making similar excuses o he ones ha elecronics companies made our

years agoha heir supply chains are oo complex or ha i is impossible o ell where

he minerals come rom. For example, a represenaive a Kraf Foods said, “[W]hen

I sared alking o my procuremen people abou [where conflic minerals may be in

Kraf’s producs]… i was geting a bi overwhelming, and I was geting a litle bi [sic]

hypervenilaing when we were going hrough all o ha.”4 Te effors o Inel and heleading ech companies since 2009 have shatered hose excuses and have proven ha

concree supply chain acion is possiblesaring wih racing suppliers back o smel-

ers, audiing smelers, and conribuing o cerificaion in Congo and he region.

Te ollowing represen noable effors by companies ouside he elecronics indusry:

• Ford and GE are carrying ou pilo projecs o es he due diligence guidance ha

was agreed on in a 2010 OECD-led mulisakeholder process. Ford and GE have also

signed on o he PPA, along wih several elecronics-componen companies.5 GE co-

ounded he smeler incenive program wih Inel and HP.

• Boeing, Northrop Grumman, United Technologies, and Lockheed Martin are piloing

he OECD guidance. Tese companies should publish he seps hey have aken o

implemen he guidance.

• Signet Jewelers, GE, and the automotive association AIAG have signed on o he

conflic-ree smeler audi program. I is a sraighorward process or oher companies

o sign on o he program a www.conflicreesmeler.org. Tese companies should

publish inormaion on how hey plan o use he program, or example requiring sup-

pliers o source rom conflic-ree smelers.

• The jewelry association Responsible Jewelry Council has begun an audi program or

jewelers called “Chain-o-Cusody Cerificaion.” However, he audis only cover

company policies and managemen sysems, raher han going hrough a jewelers’

acual purchases o gold or oher meals o check wheher hey are rom cerified

refiners and/or conflic-ree mines. More work mus be done, hereore, o comba

he flows o conflic gold.

• The mining association World Gold Council has drafed a conflic-ree sandard ha is

being piloed by some mining companies bu i is no ye finalized.

• The gold refiners’ association London Bullion Marketing Association is developing

an audi program or gold refiners in coordinaion wih he elecronics associaion

smeler audis. Te proocol or he audis has no ye been drafed, however, despie

he long amoun o ime ha has passed since he passage o Dodd-Frank.

http://www.conflictfreesmelter.org/http://www.conflictfreesmelter.org/


10/17


Many more seps remain or hese sakeholders o cach-up o he progress o he

elecronics indusry. Tere mus be assurance ha smelers are audied, supply chains

are raced o smelers, maerials are sourced rom conflic-ree mines in Congo and he

region, and he OECD guidance is implemened.

Consumer activism and legislation

Much o he progress made by companies on conflic minerals since 2010 is owed o he

U.S. legislaion passed on conflic minerals as well as he rapid growh o he conflic-ree

consumer movemen. Since i was signed ino law by Presiden Barack Obama in July

2010, Secion 1502 o he Dodd-Frank Wall Sree Reorm and Consumer Proecion Ac

has brough he conflic-minerals issue o he atenion o execuives o he approximaely

6,000 companies ha will be affeced by i.6 Alhough is final rules have no ye been

issued, he law, in broad erms, requires all companies ha use he 3 s or gold in heir

producs o race he origins o hese minerals and conduc due diligence, including an

audi, i hey originae in Congo or surrounding counries. Companies across he boardhave cied ha he law has sped up heir acions on his issue, as hey race hrough heir

supply chains in preparaion or compliance wih he legislaion.

Consumer acivism has also played a significan role in helping move ech companies

on conflic minerals over he pas hree years. Companies ranked in he op and middle

iers have been direcly argeed by aciviss and he leadership o hese companies has

impaced he enire indusry, pushing orward progress on he ground. I is also no a

coincidence ha no oher indusry affeced by he law has gone as ar as he consumer

elecronics secor in is acion on conflic minerals; his is largely due o elecronics

companies having been he main arge or consumer aciviss.

Over he pas hree years he conflic-ree movemen has demanded ha companies

suppor ederal legislaion on conflic minerals and srong rules or he law. Consumer

aciviss a college campuses, aih-based groups, socially responsible invesmen groups,

and oher civic associaions have also asked companies o publish company policies on

his issue, join indusry and mulisakeholder groups such as he EICC and he PPA, and

inves in cleanly sourced minerals rom he region ha benefi local communiies.

Trough he passage o conflic-ree resoluions a he universiy, ciy, and sae levels and

hrough direc consumer acion, aciviss have called on companies o assume responsibil-

iy or he minerals in heir supply chains, and he final producs hey produce. As a resul,

cerain companies have aken major seps orward and have helped creae a ramework or

a minerals secor in Congo ha will benefi communiies raher han armed groups.

Te delay by he SEC o release rules and regulaions or company reporing, as pre-

scribed in Secion 1502 o he Dodd-Frank Ac, has been a roadblock or progress on he


11/17


ground in Congo. Bu due o argeed consumer pressure, companies have begun o ake

he necessary seps orward o cleanly source rom Congo. As a resul o iniiaives aken

by Moorola Soluions and is consoriumas well as by elecronics componen manu-

acurer Kemelegiimae, conflic-ree mining is underway jus souh o he war-orn

Kivu provinces, proving ha i can be done in Congo. Following his lead, a consorium

o Duch companies is planning a similar projec in Souh Kivu. Furher, aciviss asked

companies o publicly express heir suppor or Secion 1502 and agains he hreaenedlawsui by he U.S. Chamber o Commerce. Since hen, our companies have voiced heir

opposiion o he lawsui hrea and called or he swif issuance o rules by he SEC, which

announced in July ha i will voe on final regulaions on Augus 22. Te release o hese

final rules should resul in more significan seps by he indusry in he coming monhs.

Te advances made over he pas hree years demonsrae he abiliy o elecronics com-

panies o se indusrywide sandards, drive orward progress on he ground, and move

oher acorsnamely he U.S. governmenoward prioriizing Congo. Te significan

movemen by companies ino he firs and second iers o he rankings shows heir iner-

es in showing leadership on issues ha he public cares deeply abouagain esablish-ing he imporance o a conflic-ree movemen among consumers.

Consumer acivism will coninue o serve as a moivaor or corporae acion ha dem-

onsraes he marke poenial or ehical producs as well as an effecive enry poin or

a naional and inernaional movemen dedicaed o peace in Congo.

Conclusion and recommendations: getting to conflict-free

Despie he progress made in he pas year by boh governmens and indusry, a longroad sill lies ahead. Te exploiaion o Congo’s mineral resources coninues o exacer-

bae conflic and insabiliy on he ground and consumers are sill largely in he dark as

o wheher or no heir producs are conflic ree. I will ake a holisic effor by muliple

governmens and indusries o regulae he flow o il legal conflic minerals. Te driver o

ha effor mus remain he demand o he conscious consumer.

Te soluion or creaing an accounable and durable sysem mus come rom policies

driven down hrough supply chains by responsible indusry acors, as well as sake-

holder governmens working o find soluions owards, peace, sabiliy, and economic

developmen in cenral Arica. In he coming year here a number o acionable seps

indusry acors can ake o do heir par:

1. Moving ahead with clean minerals from Congo: In order o help Congo develop a

clean minerals rade more quickly, more firms should join he Public-Privae Alliance

on Responsible Minerals rade. Companies should inves in projecs similar o

“Soluions or Hope” o source clean minerals ha help communiies in easern

Congo and suppor livelihood projecs o help mining communiies.


12/17


2. Ensuring that more smelters get audited: Elecronics companies should do more

oureach direcly o smelers and oher indusry cusomers need o conduc oureach

o smelers as well.

3. Making sure companies are buying from clean smelters: Companies should pro-

acively require heir suppliers o only purchase rom conflic-ree smelers once

enough are available and begin enorcing hese policies hrough audis o heirfirs-ier suppliers.

4. Getting the other industries on board: Companies rom he jewelry, auomoive,

indusrial machinery, and aerospace indusries should join he CFS audi program,

he PPA, and begin direc conflic-ree sourcing programs similar o Soluions or

Hope o help Congo develop a clean minerals rade.

5. Making conflict-free certification a transparent process: Te indusry group EICC-

GeSI should amend he Conflic-Free Smeler audi review commitee o have ull

mulisakeholder paricipaion made up o indusry, civil sociey, and governmens,similar o he PPA governance board or oher cerificaion regimes such as he Fair

Labor Associaion or he Exracive Indusries ransparency Iniiaive.

6. Preventing the legislation from being overturned and fully implement i : More

companies rom all indusries ha use conflic minerals should issue saemens mak-

ing i clear ha hey do no suppor he U.S. Chamber o Commerce’s hrea o sue he

Securiies and Exchange Commission on he conflic-minerals rules, building on he

orward-looking saemens rom Microsof, GE, Panasonic, and Moorola Soluions.

Tey should also ully implemen he legislaion hrough racing and audiing programs.


13/17


Annex: Outline and criteria for scorecard7

Te conflic-minerals rade rom easern Congo can end hrough a combinaion o

companies, governmens, and consumers aking acion o race, audi, and ceriy heir

minerals supply chain. Te Enough Projec scored elecronics companies based upon a

se o hese crieria, as well as wider acions ha would help o break he link beween

he minerals rade and conflic in Congo. Reasonable imelines are needed o success-ully achieve hese acions.

Te ull company responses are available a htp://www.raisehopeorcongo.org/com-

pany-rankings/deailed-responses.pd .

• Trace: Companies mus deermine he precise sources o he minerals/meals used

in heir producs. Effors o develop rigorous means o ensuring ha he origin and

producion volume o minerals are ransparen are reviewed.

•

Audit: Companies should have deailed examinaions o heir mineral supply chainsconduced o ensure ha a) minerals are no sourced rom conflic mines and b) no

illegal axes/bribes are paid o armed groups in Congo. Credible hird paries should

conduc or veriy hese audis.

• Certify: For consumers o be able o purchase conflic-ree elecronics made wih

Congolese minerals, a cerificaion scheme ha builds upon he lessons o he

Kimberley Process will be required. Tis would be aimed a seting up conflic-ree

mines in Congo ha help communiies. Donor governmens and indusry should

provide financial and echnical assisance o galvanize his process.

Criteria8

1. Trace: Has he company raced is suppliers o he 3 and gold meals, or 3G?

a. Has he company invesigaed and come o know precisely which companies

refine/smel9 he company’s supply o he 3G, wih hird-pary verificaion? (For

each meal, hal-poin or invesigaion, hal-poin or verificaionoal o our

poins possible)

b. Has he company published he smelers i uses or he 3G? (One poin or each

meal)

c. Has he company visied a leas wo o is smelers and inquired abou he use o

conflic minerals wihin he pas year? (wo poins possible)

http://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdfhttp://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdfhttp://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdfhttp://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdf


14/17


2. Audit: Does the company have audits conducted of its suppliers of the 3TG metals

to determine mine of origin and chain of custody? (For each quesion, one poin or

each meal)

a. Does he company have a saed policy o audiing suppliers o he 3G meals?

b. Has he company conduced inernal audis o he procuremen pracices o 3G

suppliers down o he level o refiner, a leas wihin he pas year?

c. Has he company had hird-pary audis conduced o 3G suppliers down o helevel o refiner, a leas wihin he pas year?

d. Has he company paricipaed in he working group or he Conflic-Free Smeler

validaion program? (wo poins possible)

e. Has he company provided financial suppor or audiing or 3G? (Four poins

or suppor above $100,000, wo poins or suppor beween $50,000 and

$100,000, one poin or suppor below $50,000)

f. Has he company developed a leas one verifiably conflic-ree produc, wih

independenly audied supply chains all he way o he poin o exracion? (Four

poins possible here, eiher yes or no)

3. Certify: Has the company taken concrete steps to develop an international certifica-

tion regime for the 3 T and gold minerals, in order to develop conflict-free mines in

Congo? (see definiion o cerificaion, or a clarificaion)10 (wo poins possible or

he firs wo quesions, eiher yes or no)

a. Has he company made public saemens in suppor o cerificaion?

b. Does he company have a saed policy o suppor or cerificaion?

c. Has he company provided financial suppor or cerificaion? (wo poins or

suppor above $500,000, 1.5 poins or suppor beween $200,000 and $500,000,

one poin or suppor below $200,000) Paricipaion in he Public Privae Alliance

would coun or poins here. Te PPA is a sep oward cerificaion bu is no acerificaion, as per he definiion.

d. Has he company paricipaed in he process or developing he OECD Due

Diligence Guidance or Responsible Supply Chains o Minerals rom Conflic-

Affeced and High Risk Areas and did i commi o piloing he guidance? (wo

poins possible)

Additional criteria:

4. Stakeholder engagement: Has the company had regular engagement with NGO

coalitions on the conflict minerals issue?

a. Has he company me wih NGO coaliions regarding inquiries on conflic miner-

als? (One poin possible, yes or no)

b. Has he company held regular, a leas bimonhly, communicaion wih NGO

coaliions regarding conflic minerals? (One poin possible)


15/17


5. Support for legislation: Has the company publicly supported legislation on conflict

minerals?

a. Did he company paricipae in he mulisakeholder group o NGOs, companies,

and invesors o he SEC and sign on o is leters? (wo poins possible, yes or no)

b. Did he company issue a saemen advocaing or legislaion in Europe on conflic

minerals? (wo poins possible, yes or no)

c. Did he company issue a public saemen agains he hreaened lawsui againshe SEC regulaions on conflic minerals by he U.S. Chamber o Commerce?

(wo poins possible, yes or no)

6. Environmental rankings (or inormaional purposes)

a. Greenpeace Green Elecronics Ranking

b. Newsweek Green Company Rankings


16/17


Endnotes

1 Tantalum: 1. Exotech Inc. (Florida, United States) 2. F & X(China) 3. Gannon & Scott (Arizona, United States) 4. GlobalAdvanced Metals (formerly known as Cabot Supermetals)Pennsylvania, United States 5. H.C. Starck GmbH (Germany) 6.Hi-Temp (New York, United States) 7. Mitsui Mining & Smelt -ing (Japan) 8. Plansee (Austria) 9. RFH (China) 10. SolikamskMetal (Russian Federation) 11. Telex (Pennsylvania, UnitedStates) 12. Ulba Gold (Kazakhstan). Gold: 1. Asahi PretecCorporation (Japan). 2. Ohio Precious Metals (Ohio, United

States) 3. Perth Mint Refinery (Australia) 4. Royal Canadian(Canada) 5. Tanaka Kikinzoku Kogyo K.K. (Japan). Tin: 2 smelt-ers (names not yet listed, as there are not yet three).

2 See Enough Project, “From Congress to Congo: Turning thetide on conict minerals, closing loopholes, and empower-ing miners,” forthcoming.

3 Ibid.

4 Irma Villarreal at Kraft Foods, SEC Roundtable on Section1502 of the Dodd-Frank Act, October 18, 2011. Full tran-script available at http://www.sec.gov/spotlight/conict-minerals/conflictmineralsroundtable101811-transcript.txt

5 These include Qualcomm (both OECD and PPA), Foxconn,Alcatel Lucent, Alpha (Cookson), Circuit Connect, Epic Tech-nologies, Flextronics, Foxconn (also in Solutions for Hope),Freescale, KEMET, Oracle, Plansee Group Service GmBH,Siemens AG, Texas Instruments, TriQuint, UNISEM, AIAG

(Automotive Industry Action Group), EICC & GeSI (ElectronicIndustry Citizenship Coalition and Global e-SustainabilityInitiative), and IPC (Association Connecting ElectronicsIndustries).

6 However, only approximately 1,200 companies will have tole a conict minerals report, i.e. comply with the rule.

7 The full company responses are available at http://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdf

8 Unless otherwise noted, one point will be awarded foraction on each metal in each question. In other words, for

criteria I(a), if a company has investigated and come toknow its suppliers for tantalum but not for tin, tungsten, orgold, it will receive one point out of a possible four.

9 The term smelter is used here as an overarching term toindicate a metals smelter and/or processing company.

10 Certification is understood here as a multistakeholderinternational process similar to the Kimberley and/or ForestStewardship Council processes, which would be an inter -national regime to trace, audit, and certify the 3T and goldminerals as being verifiably conflict free.

http://www.sec.gov/spotlight/conflictminerals/conflictmineralsroundtable101811-transcript.txthttp://www.sec.gov/spotlight/conflictminerals/conflictmineralsroundtable101811-transcript.txthttp://www.sec.gov/spotlight/conflictminerals/conflictmineralsroundtable101811-transcript.txthttp://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdfhttp://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdfhttp://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdfhttp://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdfhttp://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdfhttp://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdfhttp://www.raisehopeforcongo.org/company-rankings/detailed-responses.pdfhttp://www.sec.gov/spotlight/conflictminerals/conflictmineralsroundtable101811-transcript.txthttp://www.sec.gov/spotlight/conflictminerals/conflictmineralsroundtable101811-transcript.txt


17/17

Enough is a project of the Center for American Progress to end genocide and crimes against

humanity. Founded in 2007, Enough focuses on the crises in Sudan, South Sudan, eastern

Congo, and areas affected by the Lord’s Resistance Army. Enough conducts intensive field

research, develops practical policies to address these crises, and shares sensible tools to

empower citizens and groups working for change. To learn more about Enough and what

you can do to help, go to www.enoughproject.org.

corporate rankings 2012

Documents