Conflict Minerals: Dodd-Frank, the SEC's Rule...and Beyond

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Designed to reduce funding sources for those perpetrating human rights abuses and engaging in armed conflict in the Democratic Republic of the Congo ("DRC") and adjoining countries, Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") directed the U.S. Securities and Exchange Commission ("SEC") to establish regulations requiring certain issuers with "conflict minerals" that are necessary to the functionality or producton of a product manufactured by them (1) to disclose annually whether any of those minerals originated in the DRC or an adjoining country (the "conflict region"), and - if the conflict minerals did originate in the conflict region, (2) to submit a report to the SEC that includes a description of the measures taken to exercise due diligence on the source and chain of custody of their conflict minerals.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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