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 referred to in the release as "Covered Countries"), and if so, to disclose the measures the company has taken to diligence the source and chain of custody of such minerals.

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