If you are an EU importer of tin, tantalum, tungsten or gold (3TG) covered by the EU Conflict Minerals Regulation, your due diligence process must now (as of 1 January) comply with the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance. Non-compliance may have serious legal and reputational consequences for your business.
You may have listened to webinars and read white papers on the topic. However, you now have to get down to business and develop your own due diligence procedures, if you have not done so already. Conflict minerals due diligence is more than mere supplier engagement, so are you working on all the required steps?
Join our lawyers Dynda Thomas and Bernhard Maier for a four-part series of 30-minute workshops zeroing in on Steps 1 – 4 of the OECD Due Diligence Guidance and the specific actions you should be taking now to ensure that your mechanisms comply. In doing so, they will also draw on and share some valuable insights from due diligence procedures implemented by US companies to comply with the US Conflict Minerals Rule.
Agenda (all sessions start at 1 p.m. GMT)
- Thursday 4 February 2021: OECD Step 1 – Strong Company Management Systems
- Thursday 11 February 2021: OECD Step 2 – Identify and Assess Risks
- Thursday 18 February 2021: OECD Step 3 – Address and Mitigate Risks
- Thursday 25 February 2021: OECD Step 4 – Independent Third-party Audits
About the Panellists
Dynda Thomas, a partner in the Corporate Practice Group, focuses a significant portion of her practice on conflict minerals, responsible sourcing and supply chain transparency. She created and leads the firm’s Conflict Minerals team and is the founder of and key contributor to the Conflict Minerals Law blog. Since 2014, Dynda has advised on disclosure and reporting obligations; development of inquiry and diligence processes; management of relationships with consultants and auditors; drafting of contracts and policies; development of procurement policies; training of senior management and client teams; drafting of communications with customers and suppliers; analysis of CMRT disclosures; and review of data gathering and retention policies. She offers a rare combination of in-depth knowledge and real-world experience across many industry sectors.
Bernhard Maier, a lawyer in our International Dispute Resolution Practice, has over 10 years’ experience in advising governments and private sector clients on matters of public international law and foreign investment, with a particular focus on the mining sector. For example, he helped Kenya secure a win in the high-profile Cortec v. Kenya ICSID rare earths mining arbitration brought against it by an Australian mining junior following the revocation of a series of exploration licences. He also advises mining companies around the world on compliance and corporate structuring issues, including in relation to compliance with the EU CMR.