From Elm Sustainability Partners:

In our efforts to keep you updated on developments concerning conflict minerals, we send you this short note.

You may not be aware of the controversy surrounding the Uganda-based African Gold Refinery (AGR). Approximately 300 companies that filed SEC Conflict Minerals Reports listed AGR in their supply chain. Previous reports and articles raised questions about its gold sourcing practices and ownership history.

This week, the Wall Street Journal published an article about AGR and its gold sourcing. We recommend reading it along with other available information. Even though 2019 is almost halfway over, there is still time for those companies wishing to implement their risk mitigation program if they decide to do so.

Consumer-facing companies that list AGR in their 2019 conflict minerals filing are likely to face unprecedented public backlash. B2B companies may find their corporate customers (especially those leading companies that are particularly brand-conscious) will push if risk mitigation measures are not implemented. Many of those leading companies require mid-year CMRT submittals specifically to evaluate what suppliers, if any, need to make such changes.