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On 08, Jan 2014 | In | By Petermann

Conflict minerals

Conflict minerals: Disclosure and reporting obligations in the supply chain

Under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Sec. 1502), listed U.S. companies are required to disclose the origin of certain raw materials (“conflict minerals”) contained in their products. These conflict minerals, also referred to as 3TG, include the metals tin, tungsten, tantalum, and gold. These metals are used predominantly in the production of electric and electronic products and their components.

The countries of origin/trouble areas that are subject to the Dodd-Frank Act include the Democratic Republic of the Congo (DRC) and adjoining countries, such as Angola, Burundi, Sudan or Tanzania. In these countries, armed rebel conflicts are particularly often financed with the trade in conflict minerals.

Companies that are subject to the Dodd-Frank Act are therefore required to trace the conflict minerals they use back to the smelter. They are obligated to consolidate collected data and submit a comprehensive conflict minerals report to the U.S. stock market supervisory authority, the Securities and Exchange Commission (SEC), on an annual basis.

Non-listed companies are not directly affected by the Dodd-Frank Act. Nevertheless, the Dodd-Frank Act has indirect effects on these companies. As suppliers of listed U.S. companies, they are required to disclose their supply chain and provide a Certificate of Origin for conflict minerals contained in their products.