Introduction -

On August 22, 2012, the U.S. Securities and Exchange Commission (the “SEC”) adopted new rules (the “Final Rules”) pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”)[2] requiring specialized due diligence and disclosure regarding the use of “conflict minerals” by issuers registered under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). The Final Rules are intended to help end human rights abuses in the Democratic Republic of the Congo (“DRC”) and adjoining countries by reducing the financing of armed groups that benefit from commercial activity involving conflict minerals.

The conflict minerals rules affect a large number of issuers, and complying with the rules will be costly and time-consuming. Issuers that have not yet started the process of assessing their use of conflict minerals are encouraged to immediately do so. Issuers should also review and consider revising their policies and procedures affecting their supply chains in order to ensure compliance with the conflict minerals rules.