On August 22, 2012, the Securities and Exchange Commission (the
SEC) adopted annual disclosure requirements that implement Section
1502 of the Dodd-Frank Wall Street Reform and Consumer Protection
Act (Dodd-Frank), which requires disclosures relating to conflict
minerals (the Final Rules). Due to doubts as to whether they would
accomplish their intended benefits, the SEC vote to adopt the
disclosure requirements was close, with adoption passing by a 3-2
vote.
The minerals identified as "conflict minerals" are
columbite-tantalite (coltan), cassiterite, gold, wolframite, and
their derivatives—tantalum, tin, and
tungsten—as well as any other derivatives of those
minerals and any other minerals and their derivatives that the
Secretary of State identifies as conflict minerals because they are
financing conflict in the Democratic Republic of the Congo or an
adjoining country (collectively, the DRC). The new annual calendar
year disclosures will be required beginning with
