In previous posts, we have discussed the requirements and implications of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (.pdf), which requires companies that utilize certain conflict minerals to conduct and disclose due diligence on their supply chains in order to identify whether the sourcing of these minerals is supporting the conflict in the Democratic Republic of Congo. The Security and Exchange Commission released its proposed rule on conflict minerals in on December 15, 2010. The rule is open for comment until January 31, 2011.
Recently, Sarah Altschuller, one of the attorneys in our CSR practice, recorded a podcast on the SEC’s proposed conflict minerals rule for Compliance Week. The podcast is available here. Conflict minerals consist of columbite-tantalite (tantalum precursor), wolframite (tungsten precursor), cassiterite (tin precursor), and gold. As noted in the podcast, these minerals are used in the production of automobiles, jet engines, computers, cell phones, jewelry, medical equipment and many other products, and the rule will thus affect a broad range of industries.