"Upcoming conflit minerals regulation does not cover major technology companies", 9 March 2020.

...The European Union’s (EU) upcoming Conflict Minerals Regulation will come into force in January 2021 to clamp down on the mining of 3TG minerals (tin, tantalum, tungsten and gold) used to fund fighting in “conflict-affected and high-risk areas”...technology companies will not be obliged to monitor, track or otherwise act to remove the minerals from their global supply chains, a number of minerals key to the tech industry are ignored by the regulation, and companies will not even be penalised if found to be in breach of the rules...the regulation will do little to alter conditions for those on the ground living and working in conflict-affected areas, nor force the tech companies that benefit from the minerals to play their part in tackling the problem. According to Laurent Ruessmann, a competition, regulatory and trade partner from Fieldfisher’s Brussels office, one of the regulation’s main shortcomings is in how its due diligence obligations have been “watered down”...only upstream actors will have due diligence obligations, while most downstream players will continue to be locked into voluntary reporting initiatives.

This is despite the European Commission publishing a study on 20 February 2020 about due diligence requirements throughout the supply chain, which found the current voluntary measures built to mitigate adverse corporate behaviour (including human rights abuses) have failed to significantly change the way businesses manage their social, environmental and governance impacts...a better approach would be to move away from voluntary corporate governance and social responsibility models to focus on increasing the productive capacity of those living in conflict zones so they can develop their own solutions to what are essentially deeply political conflicts...