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cooperation with conlict

affected areas and support for
eu member states.

to ensure transparency on
the source of metals and ores INTERNATIONAL ELECTRONICS
SUPPLIERS
the eu legislation aims - with
the help of the Organisation

for Economic Cooperation
and Development (OECD)

- to publish an annual list of
responsible smelters and

refiners in eu and elsewhere
with the aim of raising public

accountability of compliant

operators and excluding those
whose practices are suspect.

In practice this means that

organisations would be for due diligence guidance the situation is “fluid and importers of tin, tantalum,
impacted by any new conflict and confirmation that the unstable”, favouring instead tungsten and gold will have to

minerals legislation. fortunately, components they purchased more pragmatic wording such implement a self-certiication
eu legislators adopted a much were conflict mineral free. as “conlict-affected and high system that obligates them
Consorzio
more considered approach risk areas”. to pass on due diligence di attivià
information to purchasers. t
and engaged with a wide range It’s dificult for upstream users “Who knows, per Associazioni
of organisations, officials and to determine the source although this will be essentially e gruppi d’imprese

nGos, and crucially, with the of tantalum and the other a voluntary scheme, those that it may even encourage
industries likely to be impacted minerals when it has been fail to comply will be removed US legislators review

by any proposed change in the rined and smelted, so large from the eu annual list, their amendment to
legislation. industry buyers in responsible significantly impacting on their the flawed Section

organisations simply instructed ability to trade effectively. 1502 of the Dodds-
eu legislators set out to break their suppliers to ensure that Frank Act
”
the link between minerals their purchases “should contain so there is some good news
extraction, trading and the no minerals sourced from the the eu legislation seeks to for eu based organisations

financing of armed conlicts, to DRC”. enhance and encourage in the electronic components
supply network. It’s a generally
create a market for responsibly Whilst this solution worked well supply chain due diligence
traded minerals that originate in for large publicly quoted and by; incentives linked to public better than expected outcome

conflict regions and to improve responsible organisations it procurement; financial support so far. Whilst in theory the
the ability of eu organisations had the effect of all but closing for small medium sized eu could still extend the

wherever they are in the supply down legitimate mining activity enterprises (sMes); visible geographic reach of the
chain to comply with existing in the Drc which in fact is recognition for eu organisations legislation hopefully there will

due diligence frameworks. only a minority producer of who source responsibly be no last minute amendments
these minerals, driving any from conflict affected areas; to the eu legislation and who

It could be argued that the most remaining supply underground diplomatic outreach with knows, it may even encourage
critical step taken by brussels and negatively impacting the governments in extracting, us legislators review their

was to disengage foreign selling price in line with reduced processing and consuming amendment to the lawed
Policy goals from the proposed demand. countries; raw materials section 1502 of the Dodds-

legislation, probably because diplomacy; development frank act.
EU PrOMOTION
vested interests within the eu
means it’s a struggle to arrive at OF DUE DILIgENCE

any single agreed policy. they In the eu alone it was
did not define the countries conservatively estimated

to which the legislation will that between 150,000 and
apply because by deinition 200,000 primarily “up-stream”

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