On August 22, 2012, the SEC adopted "conflict
minerals" rules that were mandated by the Dodd-Frank Wall
Street Reform and Consumer Protection Act (the "Dodd-Frank
Act"). According to the findings of the Dodd-Frank Act, the
exploitation and trade of conflict minerals originating in the
Democratic Republic of the Congo and adjoining countries is helping
to finance extreme levels of violence in that geographic area and
contributing to an emergency humanitarian situation.
Summary
Overview
The new rules impose potentially significant and extensive
diligence and, in some cases, reporting requirements on companies
that file periodic reports with the SEC. The new rules:
- Require companies for whom conflict minerals are necessary to
the functionality or production of a product manufactured by, or
contracted for manufacture by, such company to disclose whether
such conflict minerals originated in the Democratic Republic of the
Congo or in adjoining countries1 (together
