This paper examines conflict minerals disclosure (CMD) as mandated by the Dodd–Frank Act. We rely on a thorough content analysis conducted by the Responsible Sourcing Network on a sample of 122 firms that filed CMDs with the US Securities and Exchange Commission in 2015. We document that firms with long-term oriented incentives, a greater number of board meetings, strong corporate governance systems and inclusion in a sustainability index are associated with higher levels of CMD. Our results suggest that in the presence of enforcement leniency, both internal and external firm-specific factors affect strategic (non-)compliance with a mandatory social disclosure regime. We provide implications for supply chain managers, corporate reporters and policy-makers involved in the adoption of responsible sourcing strategies.

conflict minerals, Dodd–Frank Act, human rights, mandatory disclosure, social reporting, supply chain strategy,
Business Strategy and the Environment
Erasmus University Rotterdam

Dalla Via, N, & Perego, P.M. (2018). Determinants of Conflict Minerals Disclosure Under the Dodd–Frank Act. Business Strategy and the Environment, 27(6), 773–788. doi:10.1002/bse.2030