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Complying with the SECs Conflict Mineral Rules

by Christopher Cunningham and Josh Gaul


On August 22, 2012, the U.S. Securities and Exchange Commission (the “SEC”) adopted new rules (the “Conflict Minerals Rules”) pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) requiring specialized due diligence and disclosure regarding the use of “conflict minerals” by issuers registered under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). The Conflict Minerals Rules are intended to help end human rights abuses in the Democratic Republic of the Congo (“DRC”) and adjoining countries by reducing the financing of armed groups that benefit from commercial activity involving conflict minerals.