CCRcorp Sites  

The CCRcorp Network unlocks access to a world of insights, research, guides and information in a range of specialty areas.

Our Sites


A basis for research and practical guidance focusing on federal securities laws, compliance & corporate governance.


An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.


The “one stop” resource for information about responsible executive compensation practices & disclosure.

Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.


Keeping you in-the-know on environmental, social and governance developments

CAHRAs – Conflict-Affected and High Risk Areas – is a term out of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas. Anyone involved in conflict minerals will be intimately familiar with this document – as well as the laws, regulations and related initiatives which reference it – including the SEC conflict minerals rule. Even though the document is around 10 years old, it has been relegated primarily to the context of minerals/metals and Africa (and Latin America to a lesser extent). Responsible Investor reported that CAHRAs may be experiencing a break-out moment:

“Norges Bank Investment Management (NBIM), the New York City Comptroller, KLP, AP4, AP7 and Storebrand Asset Management have announced plans to support a conflict-affected area shareholder proposal at Mondelez. The resolution calls on the confectionary giant to commission an independent third-party report assessing the effectiveness of the implementation of its human rights policy (HRP) for operations in conflict-affected and high-risk areas (CAHRA), including Russia/Ukraine… the Norwegian pension fund believes Mondelez’s reporting is insufficient and wants increased transparency from the company on human rights due diligence in CAHRAs.

The two main proxy advisers [sic] are divided on the proposal. According to reports, Institutional Shareholder Services (ISS) has backed the resolution… Glass Lewis is recommending a vote against the proposal.”

Mondelez isn’t alone:

“JPMorgan Chase will also face a vote on a CAHRA-focused resolution, although investors are more divided. Filed by the Sisters of the Presentation of the Blessed Virgin Mary of Aberdeen, the proposal calls on the board to commission an independent third-party report on its due diligence process to determine whether the group’s lending, underwriting or other services in CAHRA expose it to human rights and other material risks.”

The article didn’t mention where proxy advisors stand on the bank’s proposal. I don’t recall CAHRA issues being included in shareholder proposals before. It possibly may have been a thing when conflict minerals disclosures first started, but the Mondelez and JPMorgan Chase proposals take it beyond that context and both are different. If one or both of these proposals gains substantial support, we might see more of them. At the moment, most due diligence related to CAHRAs is limited to minerals and conducted by industry programs that would have to expand greatly if this catches on.

If you aren’t already subscribed to our complimentary ESG blog, sign up here: for daily updates delivered right to you.

Back to all blogs

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