CONFLICT OF MINERALS:

 

On August 22, 2012 the U.S. Securities and Exchange Commission (SEC) adopted final rules to implement reporting and disclosure requirements related to "Conflict Minerals" as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. By May 2014, manufacturing companies that are publicly traded in the United States must disclose whether the products they manufacture or contract to manufacture contain Conflict Minerals "necessary to the functionality or production" or those products.

 

Conflict Minerals are tin, tantalum, tungsten, and gold, the sale of which determined to be financing armed conflict in the Democratic Republic of the Congo (DRC) or an adjoining country. The final rules contemplate that reporting companies must be able to trace the source of any Conflict Minerals used in their products to the smelter from which the minerals were obtained. To do this, the final rules require publicly held companies to conduct due diligence in order to identify whether products contain Conflict Minerals, but those rules do not define how due diligence is to be conducted. The recommended standard for due diligence endorsed by many industry groups, including the automotive industry, is the framework established by the Organization for Econominc Cooperation and Development (OECD), which can be found at http://www.oecd.org/daf/inv/mne/mining.htm