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March 7, 2017Mr. Michael S. PiwowarActing ChairmanUnited States Securities and Exchange Commission100 F Street, NE Washington, DC 20549Re: Comments on Reconsideration of Conflict Minerals Rule Implementation – SupplementalSubmission to February 17, 2017Dear Mr. Piwowar,As 127 investors and investor groups with over 4.8 trillion in assets under management, we arewriting to express our continued support for Section 1502 of the Dodd-Frank Wall Street Reformand Consumer Protection Act and the U.S. Securities and Exchange Commission's Conflict MineralsRule. No single law can solve all the underlying problems that are causing conflict in theDemocratic Republic of Congo (DRC) region, but since 2010, Section 1502 has demonstratedsuccess in diminishing revenue flows to militia groups. The law has also been a catalyst for positivechange in the region's mining sector, a vital step toward a more effective response by U.S.companies to address material risk in their supply chains, and has contributed to responsibleeconomic development in the DRC.As fiduciaries, with a long-term view of capital appreciation, assessing and integratingenvironmental, social, and governance (ESG) data into our investment decision-making process isnecessary and prudent. Sustainable investors value companies' responsible management of globalsupply chain risks and have been particularly concerned in recent years by the use of four minerals,referred to as "conflict minerals" to fund the continuing violence in the DRC.Conflict minerals disclosure is material to investors and has informed and improved investors'ability to: Assess social (i.e., human rights) and reputational risks in a company's supply chain. Assess a company's long-term mitigation of risks related to the supply of minerals, liability, andother material risks.The current Conflict Minerals Rule's disclosures are consistent and accessible to all investors,thereby improving efficiency in U.S. markets in allocating capital to issuers with the best overallprospects for long-term shareholder value. We understand that the transformation to a peacefuland prosperous mining industry in the DRC region has been slow and challenging. Companydisclosures on sourcing practices, combined with analysis provided by groups like ResponsibleSourcing Network on the quality of such disclosures, has provided investors with importanttransparency into relevant and material human rights risks. We consider that in order to ensurethat implementation with this rule achieves maximum impact, it is critical for the SEC to pursuerobust enforcement of the requirements.1

We believe that continued engagement and reporting on corporate activities related to conflictminerals under Section 1502 are vital for improvement on the ground. In fact the most recentstudy conducted by the International Peace Information Service (IPIS) found that 79% of tin,tantalum, and tungsten miners surveyed now work in conflict-free mines; 204 mines have beenofficially certified as conflict-free; and 75% of smelters/refiners worldwide, for the four conflictminerals, have passed audits by the Conflict-Free Sourcing Initiative or associated programs.We support that the SEC appropriately considered the costs and benefits involved and charted aworkable path forward for companies to report on the source of and due diligence processesassociated with conflict minerals. During the SEC rulemaking process, estimated costs forimplementation ranged from 390 million to 8 billion. There has only been one report by Dr. ChrisBayer, at Tulane University, on the actual cost of implementation. The report, which relied on datafrom 112 companies, calculated the total cost to be 709 million, far below the estimated 3 to 4billion highlighted in the proposed Executive Order. Consulting firm Claigan Environmental nowestimates that the average cost of compliance per company is around 20,000 per year. Anotherconsulting firm, Elm Sustainability, recently reported that actual compliance costs have “droppedsignificantly, in large part due to innovations and efficient tools available to issuers and suppliers atno cost.”Companies worldwide are under increasing scrutiny and regulation on conflict minerals from theDRC with the EU's Conflict Minerals Due Diligence which is mandatory for importers of conflictminerals and even some signals from China on possible regulation. Spurred by American leadershipon this issue, which goes back to disclosure amendment 3997 championed by Senator Brownback(R-KS) and a bipartisan coalition of nine senators, supply chain due diligence is becoming a globalnorm for responsible sourcing.As sustainable and responsible investors, we look to the U.S. Administration and the SEC tocontinue their essential role in promoting responsible management and sourcing of raw materials.Through regulated disclosures, not only do companies and investors benefit, but we all indirectlycontribute to a peaceful, prosperous, and stable conflict-free minerals trade in the DRC region,thereby further advancing respect for human rights in the global supply chains of U.S. companies.For any questions on the comment submission, please contact Lauren Compere, Boston CommonAsset Management aton behalf of this investor group.Lead Investor & Investor Group SignatoriesLauren CompereManaging DirectorBoston Common Asset ManagementJosh ZinnerCEOICCR2

Pat ZeregaSr. Director, Shareholder AdvocacyMercy Investment Services, Inc.Patricia JurewiczDirectorResponsible Sourcing NetworkSusan BakerVice President, Shareholder AdvocacyTrillium Asset ManagementLisa WollCEOUS SIF: The Forum for Sustainable andResponsible Investmentcc:Mr. Keith Kellogg, Acting National Security Advisor, National Security CouncilMr. Rex Tillerson, Secretary of State3

Investor Signatories – updated February 17, 2017Dennis van der PuttenHead of Responsible InvestmentACTIAMSteve MasonDirector of Brethren Values InvestingChurch of the Brethren Benefit TrustKathleen WoodsChair, Corporate Responsibility CommitteeAdrian Dominican Sisters, Portfolio AdvisoryBoardShelley AlpernDirector of Social Research & ShareholderAdvocacyClean Yield Asset ManagementBrandon ReesDeputy Director, Office of InvestmentAFL-CIOEllen FriedmanExecutive DirectorCompton FoundationAndrew FriedmanAJF Financial Services, Inc.Karen Watson, CFAChief Investment OfficerCongregation of St. JosephPeter LundkvistHead of Corporate GovernanceAP3 Tredje AP-fondenJohn WilsonHead of Corporate Governance, Engagement andResearchCornerstone Capital GroupArne LööwHead of Corporate GovernanceAP4 (Fjärde AP-fonden)Ann RobertsDana Investment AdvisorsAnna PotManager, Global Responsible Investment &GovernanceAPG Asset ManagementSister Louise Gallahue, D.C.ProvincialDaughters of Charity, Province of St LouiseFrank RauscherSenior PrincipalAquinas AssociatesTory Dietel HoppsManaging PartnerDietelPartnersKatherine StearnsIARArc Advisers, LLCSusan VickersVice President, Corporate ResponsibilityDignity HealthBashar QasemCEOAzzad Asset ManagementValerie HeinonenDirector, Shareholder AdvocacyDominican Sisters of HopeHelena Viñes FiestasHead of Sustainability ResearchBNP Paribas Investment PartnersJudy Lu McDonaldCongregational RepresentativeDominican Sisters of San RafaelSteve MasonDirector of Brethren Values InvestingBrethren Foundation Funds Inc.Eileen GannonDominican Sisters of Sparkill4

Ise BoschDreilinden gGmbHJohann KlaassenChief Investment OfficerHorizons Sustainable Financial ServicesLouise HedbergHead of Corporate Governance and SustainabilityEast CapitalThomas O'MalleyGlobal Head of Corporate GovernanceHSBC Global Asset Management (UK) ltdEsmé van HerwijnenResponsible Investment AnalystEdenTree Investment ManagementRon RobinsFounder, Analyst, TutorInvesting for the SoulLuca MattiazziGeneral ManagerEtica SgrChristine JantzPresidentJantz Management LLCChris MeyerManager, Advocacy and ResearchEverence and the Praxis Mutual FundsHelen BeichelPresidentFattail Financial Advisory GrpHanna WaltsgottResponsible Investment AnalystKempen Capital ManagementJennifer HallTreasurerLeadership Team of Sisters of Providence, MotherJoseph ProvinceTaylor ReedAssociateFigure 8 Investment StrategiesHolly A. TestaDirector, Shareowner EngagementFirst Affirmative Financial NetworkMeryam OmiHead of Sustainability & Responsible InvestmentStrategyLegal & General Investment ManagementOssian EkdahlChief Active Ownership OfficerFörsta AP-fonden (AP1)Tammy McHaleVP - Business AffairsMarywood UniversitySusan Ernster, FSPATreasurerFranciscan Sisters of Perpetual Adoration, Inc.Lisa HeinzCFOMennonite Education AgencyJeffery W. PerkinsExecutive DirectorFriends Fiduciary CorporationJerry JuddSenior Vice President & TreasurerMercy HealthDavid SchreiberCFPGreenvest/FWGBarbara JenningsDirectorMidwest Coalition for Responsible InvestmentTim GoodmanDirectorHermes EOSLuan JeniferExecutive Vice PresidentMiller/Howard Investments, Inc.5

Fr. Seamus Finn OMIMissionary Oblates of Mary ImmaculateMeredith BlockVice PresidentRockefeller & Co; Sustainability & Impact GroupKarlijn Van LieropHead of Responsible Investment & GovernanceMNLinda JansenAssistant TreasurerSchool Sisters of Notre DameMichael KramerManaging PartnerNatural InvestmentsCorporate Responsibility CommitteeSchool Sisters of Notre Dame - Central PacificProvinceMichelle de CordovaDirector, Corporate Engagement & Public PolicyNEI InvestmentsUlrika DanielsonHead of CommunicationsSecond Swedish National Pension Fund (AP2)Bruce T. Herbert, AIFChief ExecutiveNewground Social InvestmentKevin ThomasDirector of Shareholder EngagementShareholder Association for Research & EducationJulie GoodridgeCEONorthStar Asset Management, Inc.Richard W. TorgersonCEOSharePower Responsible Investing, Inc.Judy Byron, OPNorthwest Coalition for Responsible InvestmentSister Mary Beth Hamm, SSJCoordinator: Justice, Peace and Integrity ofCreationSisters of Bon Secours USAMarcus RobertsonPension Board ChairPension Plan of The United Church of CanadaBarbara Joseph LammersCorporate Responsibility CoordinatorSisters of Charity of NazarethJelena Stamenkova van RumptAdvisor Responsible InvestmentPGGMSr. Mary HealeySisters of Charity, BVMKrista StrohofferFinancial Advisor, CFP Principled Investing LLCMary Burns, SCRepresentativeSisters of Charity, HalifaxKeith JohnsonChairReinhart Institutional Investor ServicesSr. Ruth SchaafSocially Responsible Investments CoordinatorSisters of St. DominicCathy MinhotoTreasurerRelisious of the Sacred Heart of Mary WAPSr. Joan Agro, OPLeadership Team CouncilorSisters of St. Dominic of Blauvelt, N.Y.Carola van LamoenHead Governance and Active OwnershipRobecoSr. Patricia A. Daly, OPCorporate Responsibility RepresentativeSisters of St. Dominic of Caldwell NJ6