In February 2020, Ethical Consumer viewed Boots' website and found that the company sold a number of own-brand electrical items, including batteries. Ethical Consumer searched the website, along with that of the parent company Walgreens Boots Alliance, for the company's policy on the use conflict minerals. No policy or statement could be found.
Walgreens Boots Alliance appeared not to have submitted Form SD filings with SEC (which reports on conflict minerals).
Conflict minerals are minerals mined in conditions of armed conflict and human rights abuses, notably in the eastern provinces of the Democratic Republic of Congo (DRC). The minerals in question are Tantalum, Tin, Tungsten and Gold (3TG for short) and are key components of electronic devices, including electric shavers.
Ethical Consumer deemed it necessary for any company manufacturing electronics to have a policy on the sourcing of conflict minerals. Such a policy would articulate the company's commitment to conflict free sourcing of 3TG minerals and its commitment to continue ensuring due diligence on the issue. The policy should also state that it intends to continue sourcing from the DRC region in order to avoid an embargo, which would hurt local workers even more.
A company should also demonstrate its commitment to the issue of conflict minerals by supporting conflict free initiatives in the region either through membership of a multi-stakeholder initiative supporting the conflict-free minerals trade (such as Conflict Free Sourcing Initiative (CFSI), Public-Private Alliance for Responsible Minerals Trade (PPA) and industry initiatives such as JEITA Responsible Conflict Minerals Working Group) and / or financially supporting in-region mining initiatives (such as KEMET “Partnership for Social and Economic Sustainability”, Conflict-Free Tin Initiative (CFTI), ITRI Tin Supply Chain Initiative (iTSCi), Solutions for Hope).
A strong conflict minerals policy would also:
- require suppliers to adopt a robust 3TG conflict minerals policy and programme equivalent to the company.
- include details of the steps it will take to identify, assess, mitigate and respond to risks within its supply chain.
- use conflict minerals reporting templates by Conflict Free Sourcing Initiative (or may be referred to as EICC-GeSi) or OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
- include a commitment (from the company and supplier) to only using 3TG minerals from smelters that have been audited and verified as conflict free by the Conflict Free Smelter Program, or an equivalent, as they become available
- list in detail the smelters or refiners (SORs)
Since Boots had none of these things, it received Ethical Consumer's worst rating for conflict minerals and lost a whole mark under Human Rights and Habitats and Resources.