Conflict Minerals

* In 2010, the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act was passed concerning “conflict minerals” originating from the Democratic Republic of the Congo (DRC) or adjoining countries. The SEC published final rules associated with the disclosure of the source of conflict minerals by U.S. publicly traded companies (see the rules at The rules reference the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, (, which guides suppliers to establish policies, due diligence frameworks and management systems.

* In 2017, Regulation(EU) 2017/821 of the European Parliament and of the European Council of 17 May 2017 was passed concerning supply chain due diligence obligations for Union importers of tin, tantalum and tungsten , their ores, and gold originating from conflict-affected and high-risk areas (see regulation at

** See information on the Responsible Minerals Initiative (

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