Conflict Due Diligence by European Companies

This briefing paper provides an overview of the due diligence efforts of 186 companies that are listed in Europe and make use of the minerals covered by Dodd Frank 1502. The information they make publicly available regarding their approach to the issue of ‘conflict minerals’ is assessed. Those companies that have a dual listing in the US – and are therefore required to comply with Dodd Frank 1502 – are compared with those companies who are only listed in Europe. This briefing paper also looks more in-depth into the specifics of the due diligence efforts of those companies that refer to conflict minerals on their website.