On August 22, 2012, the Securities and Exchange Commission (“SEC”) adopted a final rule implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that requires certain disclosures related to the use of “conflict minerals” that originated in the Democratic Republic of the Congo and adjoining countries (together, the “DRC Countries”).

Companies Subject to the Final Rule -

The final rule adopted by the SEC applies to any company that files reports with the SEC under Section 13(a) or Section 15(d) of the Securities Exchange Act of 1934 (the “Exchange Act”), including U.S.companies and foreign private issuers, for which the use of conflict minerals is necessary to the functionality or production of a product manufactured or contracted to be manufactured by such company. Under the final rule, “conflict minerals” are defined as cassiterite (used to make tin), columbite-tantalite (from which tantalum is extracted), gold, wolframite (used to produce tungsten), or their derivatives, or any other minerals (or their derivatives) determined by the U.S. Secretary of State to be financing conflict in the DRC Countries. Conflict minerals are used in electronic components and products including, but not limited to, mobile telephones, computers, videogame consoles, digital cameras and jet engine components. The SEC estimates that almost 6,000 U.S. and foreign companies will need to comply with the conflict minerals rule.

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