Dear Chairman and Commissioners,
The International Corporate Accountability Roundtable ("ICAR") and Global Witness submit this comment to address issues pertaining to the rulemaking for Section 1502 that were raised in the Roundtable, held on October 18th, 2011, and to reiterate certain key points from our previous submissions.
At the outset, we urge the Securities and Exchange Commission (Commission) to issue final rules no later than December 2011 as Congress intended for this law to immediately address the urgent humanitarian situation in the eastern Democratic Republic of Congo (DRC) by curbing the trade in conflict minerals. We also reiterate our call that final rules allow no phase-ins or delays in implementation. We believe any further delays, including delays in reporting requirements, frustrate the intent of the law, will slow down progress towards putting the necessary due diligence processes in place to establish a trade in clean minerals in eastern Congo and will enable continued financing to the armed groups that prey upon the local population...
To view the full submission, click ICAR GW letter to SEC November 1 2011