Tag Archives: Payson

Tulane University Post Mortem Conflict Minerals Implementation Cost Analysis

Tulane University is seeking input from companies that implemented conflict minerals compliance programs under Section 1502 of the Dodd-Frank Act. This study will gather data on actual implementation costs and externalities related to company activities behind the first Form SD/CMR filings.

Dr. Chris Bayer, who authored the University’s original cost analysis of the SEC proposed regulation in 2011, will act as the study coordinator, providing continuity of knowledge and expertise.  Several major industry associations from a spectrum of industry sectors are suggesting that their members participate in the study.  

Given the credibility that the SEC gave to the first Tulane cost analysis in 2011, we believe that this study will also be well received by regulators and policymakers.  

All stakeholders stand to benefit from the findings, which will reveal realities of Section 1502 regulatory compliance.  More information about this study can be found at  http://www.payson.tulane.edu/welcome-tulanes-conflict-minerals-post-filing-survey

The deadline for participation is July 31, 2014, so don’t delay.

Tulane’s Payson Center Announces New Conflict Minerals Compliance Cost Survey

Following up on Tulane’s seminal cost analysis of the SEC’s 2010 proposed rule on conflict minerals, the University has announced that it is planning a retrospective analysis of the rule’s actual implementation costs.  The survey will launch after the first SEC filing deadline and the University hopes to capture actual cost data from those who were obligated to comply with Dodd Frank Section 1502, or perform tasks supporting customers with their compliance.

Chris Bayer, who is leading the study for the University said, “In order to trace whether conflict minerals enter their supply chains, companies around the globe have, since 2011, revisited their company-level policies and procedures, updated or created IT infrastructure, resulting in the dedication of millions of person-hours and the expenditure of billions of dollars.  With macro-level data on the modalities, costs, and externalities of compliance with Dodd Frank section 1502, stakeholders in the law-making, law-implementing, and law-abiding sectors may appreciate these aggregated inputs and effects.  In June 2014 Tulane University intends to get to the bottom of this matter by launching a representative survey after companies have filed their Form SD.”

Tulane, Payson Release Survey on Conflict Minerals Implementation Costs

Tulane University Law School and its Payson Center for International Development have released a survey tool seeking information from industry on implementation status, efforts, costs and perceived advantages related to the SEC conflict minerals rule promulgated under Section 1502 of the Dodd-Frank Act.

The survey is estimated to take 15 minutes to complete.

Based on the research protocol, participants must contact relevant trade/industry associations in order to obtain a password to complete the questionnaire.

Tulane and Payson previously issued a highly regarded and widely-referenced economic impact analysis of the proposed SEC regulation in 2011. SEC considered that study, along with the cost impact analysis from National Association of Manufacturers, to be “the most useful frameworks for considering costs”.

Other recent and somewhat similar surveys have been published from consulting and audit firms. But given the established credibility and academic impartiality of Tulane/Payson, this survey may provide other perspectives and results.

New Economic Analysis of Conflict Minerals Rule Implementation from Tulane University Law School’s Payson Center for International Development

A new study on the economic impact of SEC proposed conflict minerals rule was released earlier this week by Tulane University.  The study evaluated cost estimates from SEC , National Association of Manufacturers (NAM) and IPC and provides what they refer to as a “Third Economic Impact Model”.

The study is available free of charge here.

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Elm, Conflict Minerals Cited in Report to US Department of Labor on Ethical, Sustainable Agricultural Supply Chain Systems

A significant report was published today by the Payson Center for International Development and Technology Transfer at Tulane University for the US Department of Labor.  The report, titled Oversight of Public and Private Initiatives to Eliminate the Worst Forms of Child Labor in the Cocoa Sector in Côte d’Ivoire and Ghana, March 31, 2011, reviews the progress made under the industry’s voluntary International Cocoa Initiative (ICI) created in 2002 to identify, monitor and prevent child labor in the cocoa farms of Ghana and the Ivory Coast.

The study provides the following conclusions on the effectiveness and validity of the cocoa industry’s self regulation for supply chain traceability:

… we conclude that Industry’s “certification” model does not yet conform with ISO 65 standards of certification. Industry has only partly established bodies with the appropriate mandate, and has not finalized the required processes to develop a “credible” certification system.

… These mixed results seen over the past decade of Industry self-regulation leave unanswered the question of “is Industry able to self-regulate in the absence of enforceable legal repercussions.”

The authors looked to potential analogs or solutions, discussing the US Conflict Minerals Law enacted as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.  In doing so, the study included excerpts from Elm’s February 21, 2011 article on the Conflict Minerals Law published at MetalMiner.com, and continued:

… this type of regulation has the potential to tangibly address human rights concerns surrounding conflict minerals and invites the business community to become part of the solution. In light of the protracted human rights issues that also persist in the cocoa sectors of Côte d’Ivoire and Ghana, this type of approach may be considered appropriate for the cocoa/chocolate industry as well.

The study’s conclusions and recommendations stated:

… mandated disclosure [under the US Conflict Minerals Law], if applied to the cocoa industry, would have the potential to encourage more due diligence and transparent sourcing on the part of companies operating in the cocoa market … in light of the mixed results seen with industry self- regulation over the past decade a legal framework may be more effective in holding companies accountable to enforce the guidelines. [emphasis in original]