With the SEC vote on the conflict minerals rule set for tomorrow (August 22, 2012), I decided to write this short blog and answer some of the questions that I have been receiving from different stakeholders.
1. Does Intel support the pending regulation?
Our public position has always been that we support government involvement in this issue including fair and timely regulations that align with our own efforts to create a conflict-free supply chain. We were working on this issue before there was a proposed regulation and we believe the rule will be helpful in bringing others to the table and maintaining broad momentum on this important issue.
2. What are your thoughts about the rule related to compliance, costs, etc?
We haven’t seen the final rule (assuming it’s approved) so it will take some time to go through it and understand the details.
3. Did Intel do any work on the development of the SEC rule?
We were working on this issue prior to the rulemaking processes. Clearly our efforts have been targeted towards putting the systems and processes in place to establish a conflict-free supply chain. We have a published a white paper which describes in detail our ongoing efforts on this issue, and we shared that white paper with the SEC; also, Intel’s leadership was referenced in congressional testimony supporting the SEC rulemaking. Additionally, we have already put information in our most recent Form 10-K report referencing conflict minerals.
4. Some industry groups have suggested they may bring litigation against the rule. What’s Intel’s position on that?
I’m not going to speculate on potential actions that industry groups might take. As I said, Intel has publicly stated our support for fair and timely rules. We believe rules will be helpful in bringing others to the table and maintaining broad momentum on this important issue.
5. Intel has been criticized for being a member of industry groups that have raised concerns regarding the rule. How do you reconcile this apparent conflict?
We recognize that our positions do not always align 100% with those of the industry and trade organizations to which we belong, given the wide range of issues addressed by these organizations. In areas where we may have differences, we often publish our position separately as we have done with our conflict minerals white paper. Large trade associations such as U.S. Chamber of Commerce and the National Association of Manufacturers’ have many members and adopt positions on numerous issues, and it is not realistic or necessary to assume we will agree with each position of each association of which Intel is a member. This does not detract from, or distract us from, our substantive efforts with regard to conflict-free minerals.
6. What’s next on the horizon for Intel regarding conflict minerals?
Obviously, we are going to thoroughly review the rule, assuming it’s approved, and determine how our already existing efforts align with the new rule. We are going to continue to pursue our goal of manufacture the world’s first microprocessor fully validated as conflict-free across all four minerals by the end of 2013; and we are going to continue to work with our industry partners in the Electronic Industry Citizenship Coalition in support of the conflict-free smelter program. We are also proud of the recent recognition and top ranking we received from the Enough Project for our work on this complex and challenging issue.