Conflict Minerals Policy

In 2010, Congress enacted Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) to address the exploitation and trade of certain minerals which contribute to violence and human rights abuses in the Democratic Republic of the Congo (the “DRC”) and its neighboring countries. In 2012, the SEC adopted rules implementing Section 1502 (the “Conflict Minerals Rules”), which require public companies to annually disclose: (i) information about whether the products they manufacture or contract to manufacture contain Conflict Minerals that originated in any “Covered Countries,” and if so, (ii) information about the source and supply chain of those Conflict Minerals. It is expected that the Conflict Minerals Rules will reduce a significant source of funding for armed groups that are committing human rights abuses in the DRC and the other Covered Countries.

“Conflict Minerals” include gold, columbite-tantalite (coltan), cassiterite, and wolframite, as well as their derivatives, tantalum, tin, and tungsten. The “Covered Countries” include the DRC, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola.

Conflict Minerals Policy

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