Investors Emphasize Importance of Dodd-Frank Act Compliance

Investors Emphasize Importance of Dodd-Frank Act Compliance

Investors controlling $1.2 trillion in assets issued a statement on May 31, 2018, warning companies that compliance with the Dodd-Frank Wall Street Reform and Consumer Protection Act is still necessary and expected.

The statement, signed by 47 investors, reiterated that conflict minerals reporting for private companies is a legal requirement under Section 1502 of the Dodd-Frank Act. Additionally, investors are concerned that failure to report will increase the risk of human rights violations in supply chains, particularly in the

Some companies interpreted April 2017 comments by outgoing Securities and Exchange (SEC) Commission Commissioner Michael Piwowar about the SEC’s enforcement, or lack thereof, to imply they can decline to report on the use of conflict minerals.


Do you know your requirements under the Dodd-Frank Act? Download The Conflict Mineral Handbook: Your Guide to Compliance in 2018 to learn more.


This order is the latest in a series of WROs issued by the agency, including a ban on toys imported from a Chinese manufacturer. These highlight the ongoing success of the U.S. Trade Facilitation and Trade Enforcement Act in increasing the ability of the U.S. CBPA to prevent the import of products linked to forced labor.

However, while some companies may feel the SEC’s enforcement policies are vague, these investors have made it clear that Section 1502 of the Dodd-Frank Act isn’t optional — and companies that choose not to comply could face legal action.

What Is Section 1502 of the Dodd-Frank Act?

The Dodd-Frank Act is a U.S. federal law introduced in 2010 that sought to reform financial regulations following the 2007–08 financial crisis. This act had lasting effects on all federal U.S. regulatory agencies, with Section 1502 placing specific requirements on publicly-traded companies to ensure the raw materials used to manufacture their products are not tied to conflict in the DRC.

Conflict minerals reports are important to investors, who are becoming increasingly concerned about the social impact of the companies they invest in. As such, responsible mineral sourcing will continue to play a significant role in investment decision-making, particularly when the EU Conflict Mineral Regulation takes effect in January 2021 and industry-driven efforts for voluntary disclosures grow.  The scope of conflict mineral reporting may expand in the future, as companies broaden their programs to include minerals such as cobalt, mica, talc, nickel, iron and copper.

Assent Compliance’s Corporate Responsibility Suite allows companies to effectively survey the supply chain using the industry-standard Conflict Minerals Reporting Template, and collect and validate data.

To learn more about how Assent’s Corporate Responsibility Suite can simplify your data collection and reporting processes, contact us at info@assentcompliance.com.

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