Background
The Dodd-Frank Act (the “Act”) was signed into law on July 21, 2010. Section 1502 was included to help curb violence and other human rights violations in the Democratic Republic of Congo (the “DRC”) and neighboring countries (Angola, Burundi, Central African Republic, Congo Republic, Rwanda, Sudan, Tanzania, Uganda, and Zambia) (collectively the “DRC countries”).
Under Section 1502, a public company that manufactures products using conflict minerals must disclose the source(s) of its conflict minerals on its website and in annual reports filed with the SEC. The term “conflict mineral” is defined in the Act to include the following: (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the DRC countries. The Secretary of State is also required to produce a map of mineral-rich zones, trade routes, and areas under the control of armed groups in the DRC countries.
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