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A new report issued by the law firm Amsterdam & Partners, representing the government of the Democratic Republic of Congo according to Barron’s, accuses Apple, Intel, Sony, Motorola, Lockheed Martin and others of buying tin, tantalum, tungsten and gold from Rwanda that “have been smuggled from the DRC, in a context of violent exploitation.” The new update 53-page report from Amsterdam & Partners is particularly pointed with lengthy accusations against Apple and the predominant upstream due diligence scheme ITSCI:

“Due diligence teams from big tech companies such as Apple, Intel, Sony, Motorola & Lockheed Martin have also been informed that the minerals purchased from Rwanda have been smuggled from the DRC, in a context of violent exploitation. These minerals are therefore neither ‘conflict-free’ nor legally procured, yet tech companies use them anyhow to manufacture their products, from laptops to airplanes. Ironically, Rwanda is portrayed as a safe and efficient trading hub in the mineral supply chain. Consumers have been led to believe that their iPhones and Sony earbuds have not helped finance war in Africa’s Great Lakes region if they are made with metals exported from Rwanda…

Individuals working for industry-led regulators, downstream companies on the supply chain and third-party auditors, are therefore liable for knowingly profiting from the commercialization of trafficked materials. Given the extensive evidence of laundering that has been documented by investigators from the United Nations and the NGO Global Witness, these parties risk liability for racketeering, aiding and abetting, trade-based money laundering and fraudulently misrepresenting the origin of the minerals they purchase in Securities and Exchange Commission disclosures.”

These minerals are called “conflict minerals” by the US SEC, the EU and the OECD. In the US, publicly-traded companies are required to report on their use of conflict minerals in products sold, and the due diligence efforts undertaken to determine the source of the minerals and if they were mined or processed in facilities that fund armed groups that contribute to civil unrest and violence in central Africa. The SEC’s final rule on conflict minerals was published in November 2012 and the first disclosures were filed in 2014. Since that time, reports occasionally surface claims that illicit ore/minerals are entering the supply chain and escaping identification by the various minerals due diligence schemes/mechanisms.

Reports such as this create reputational risks for companies named, but the current era of greenwashing could mean more risks/liabilities for those identified. It is possible that organizations and auditors involved in conflict minerals due diligence activities could also feel more heat as well. Even though this marks the tenth year of conflict mineral disclosures, it would be prudent to view it through the lens of potential greenwashing risks this year. There’s still a month before the SEC regulatory deadline.

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile