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Conflict Minerals: Recent Shareholder Engagement

| April 25, 2017
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We wanted to share a quick update from Trillium’s progressive work with Conflict Minerals and human rights.  Trillium sub-advises a mutual fund which is held in our Fossil Fuel Free portfolio.

Trillium Asset Management recently sent a letter to the Securities and Exchange Commission (SEC) reaffirming their support for the implementation of Section 1502, the Conflict Minerals Rule, of the Dodd-Frank Wall Street Reform and Consumer Protection Act. This letter follows a joint statement sent on March 7th in which Trillium and five other lead investors led a coalition of 127 investors and groups representing more than $4.8 trillion in AUM to express continued support of the Conflict Minerals Rule.

Their letter was submitted in response to the January 31, 2017 Statement on the Commission’s Conflict Minerals Rule, in which SEC staff were directed to reconsider whether the 2014 guidance on the conflict minerals rule was still appropriate. The statement also requested comments from the public on the guidance and as a result, over 1,000 interested parties responded. The Conflict Minerals Rule, which became law in 2010, requires specified companies to undertake source and chain of custody due diligence to determine whether certain minerals (tin, tantalum, tungsten, and gold, or “3TG”) in their products may be contributing to conflict in the Democratic Republic of Congo (DRC) and surrounding countries.

“The Conflict Mineral Rule has given investors disclosures relevant to human rights risks that they deserve when making investment decisions,” stated Susan Baker, Vice President of Shareholder Advocacy at Trillium in a March 2017 press release. “Borne out of bipartisan legislation it has inspired transparency in corporate supply chains and helped neutralize one of the key economic drivers of conflict in the DRC. As long-term investors, we believe the rule is a positive and important step in the right direction. To weaken 1502, in our view, raises inconsistencies with the SEC’s investor protection mandate.”

Trillium’s support and advocacy on this issue dates back to 2011 when we joined a diverse group of stakeholders including investors, human rights activists, and businesses to provide recommendations to the SEC. We believe that the Rule provides investors the information needed to make sound financial investments and to ensure that the companies in which we invest are not associated, either directly or indirectly, with significant human rights associated with conflict

We hope you find this on-the-ground Shareholder Engagement story interesting and insightful.  As always, feel free to pass these articles to others or share your comments with us!

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