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2016 Global Law Scholars Research Brief

1,001 Issuers' Compliance with the Dodd-Frank Conflict Minerals Rule

Global Law Scholars Class of 2016

In an effort to understand the potential of securities law as a means of promoting socially responsible sourcing by companies, the Global Law Scholars Class of 2016 reviewed the disclosures of all 1,001 issuers obligated to file a report on Conflict Minerals in their supply chain with the U.S. Securities and Exchange Commission (SEC) in 2013. Based on consultation with issuers, law firms, and responsible minerals sourcing advocates, indicators were developed to assess whether companies were following (1) the letter of the Dodd Frank Act's Conflict Mineral Rule, by reporting on their due diligence and facilities used for processing tin, tantalum, tungsten, and gold in their supply chain; as well as (2) the spirit of the Rule, by committing to develop a conflict minerals policy, updating contractual conditions with their suppliers, or engaging in other efforts to clean up their supply chains. While about one third of the companies met all measured letter of the law requirements, only four percent scored perfectly on our measured spirit of the law indicators. Factors that correlated with stronger letter and spirit of the law scores for companies include internet visibility, financial health, industry location, participation in the Conflict-Free Sourcing Initiative, and funding from socially responsible investors.

Members of the Global Law Scholars Class of 2016

Alice Barrett

Nicholas Brock

Ena Cefo

Ivana Djak

Jacqueline Johnston

Reed Koenig

Sarah Lohschelder

Mina Miljevic

Zana Operta

Beth Palkovic

Jae-Hyong Shim

Kathy Shin

Hannelore Sklar

Delia Solomon

James Strawbridge

Weiwei He

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