Boston Common on the SEC Rule on Conflict Minerals
Over the past two years, Boston Common Asset Management, LLC (“Boston Common”), through specific recommendations, letter-writing campaigns, and meetings with SEC rule-making staff and Commissioners, has played a vital role as one of the lead investors providing substantive input to The Dodd-Frank Act’s Conflict Mineral Disclosure provision (Section 1502). Boston Common has also been an active player in a Multi-Stakeholder Group comprised of a number of Fortune 500 companies, specifically from the electronics sector, human rights organizations and other investors.
Below are links to the SEC submissions from both investors and the Multi-Stakeholder Group (MSG)
Investor Submissions to the SEC
From 2010-2012, Boston Common was one of the lead investors who coordinated input to The Dodd-Frank Act’s Conflict Mineral Disclosure provision (Section 1502). Each of these letters were signed by 49 socially responsible investors (SRI), all of which made detailed recommendations to the SEC regarding which companies should file the Conflict Minerals Reports, and how those companies should file.
Investors – November 2010
http://www.sec.gov/comments/df-title-xv/specialized-disclosures/specializeddisclosures-54.htm
Investors – March 2011
http://www.sec.gov/comments/s7-40-10/s74010-158.pdf
February 1, 2012
http://www.sec.gov/comments/s7-40-10/s74010-475.pdf
Multi-Stakeholder Group Submissions to the SEC
Over the last two years, Boston Common has also participated in a coalition of Fortune 500companies, investors, and human rights organizations in a Multi-Stakeholder Group (MSG) that submitted four joint letters to the SEC recommending an appropriate amount of transparency and accountability in mineral supply chains.
Multi-Stakeholder Group – November 2010
Multi-Stakeholder Group – March 2011
http://www.sec.gov/comments/s7-40-10/s74010-152.pdf
Multi-Stakeholder Group – August 2011
http://www.sec.gov/comments/s7-40-10/s74010-302.pdf
Multi-Stakeholder Group – November 2011
http://www.sec.gov/comments/s7-40-10/s74010-410.pdf
Multi-Stakeholder Group – August 2012:
