October 24, 2014 – October 31, 2014 The summaries provided in this Weekly Recap do not necessarily represent the views of Squire Patton Boggs (US) LLP and should not be deemed to be endorsements of them. The Recap is intended to be a compilation of articles and events to encourage discussion within the conflict minerals community and to keep our readers updated on the most recent developments.

SEC Commissioner Speaks: SEC Should Not Handle Conflict Minerals Reports

John Kester of the Wall Street Journal reports on Commissioner Daniel Gallagher, Jr.’s speech at Fordham University School of Law. Commissioner Gallagher stated, “Those [Dodd-Frank] mandates distract from the SEC’s proper regulatory oversight and strap its limited resources.” Commissioner Gallagher does not believe that the SEC has the appropriate resources to handle conflict minerals reports and instead thinks that the Department of Defense or Department of State would be better-suited.

As for background, Commissioner Gallagher is one of five SEC commissioners. His term expires in 2016.

Socially Responsible Investors Urge European Parliament to Make Proposed EU Conflict Minerals Regulation More Compatible with U.S. Rule

Twenty-four (24) signatories, including Trillium Asset Management, Boston Common Asset Management, and Eurosif, released a joint statement urging the European Parliament, European Commission, and European Council to adopt a European Union conflict minerals rule that is similar to the U.S. conflict minerals rule.

The statement reads, “We recommend, however, that the regulation proposed in March 2014 be amended to ensure an important level of harmonization between the European proposal and currently operational US federal rules on corporate conflict minerals due diligence and reporting. Thus, the undersigned sustainable and responsible global investors and investment organizations, representing 855 billion euros in assets under management, are writing to urge the adoption of legislation on conflict minerals (tin, tantalum, tungsten, and gold, or “3TG”) that better aligns with Section 1502 of the US Dodd-Frank Wall Street Reform and Consumer Protection.”

Specifically, the signatories recommend:

  1. The reporting mechanism should be mandatory.
  2. The rule should apply to any European company that manufactures or contracts to manufacture products containing 3TG that is necessary to product functionality or manufacture.