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Conflict Minerals

Understanding the new Dodd-Frank Section 1502 disclosure requirements

The U.S. Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act), which was signed into law on July 21, 2010. Section 1502 of the Act is a provision related to sourcing ‘conflict minerals.’ The term ‘conflict mineral’ is defined as:

  • Columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted);
  • Cassiterite (the metal ore from which tin is extracted);
  • Gold;
  • Wolframite (the metal ore from which tungsten is extracted); or their derivatives.
  • Conflict minerals are also referred to as "3TG". Additionally, any other mineral or its derivatives could be added if determined by the Secretary of State to be financing conflict in the DRC countries.

Section 1502 instructs the U.S. Securities and Exchange Commission (SEC), in consultation with the U.S. Department of State, to promulgate regulations requiring certain companies to submit annually a description of measures taken to exercise due diligence on the source and chain of custody of "conflict minerals".

The intent of the provision is to deter through increased transparency of companies’ sourcing practices — the extreme violence and human rights violations in the Democratic Republic of Congo (DRC) and neighboring countries funded by the exploitation and trade of certain minerals.

Featured insight

Conflict minerals: Evolving compliance
Publication: 12-page PDF

Industry insight

Conflict minerals: The retail perspective
Publication: 8-page PDF

Reporting trends

Heads up —  Navigating next steps after the year 1 Form SD and conflict minerals reporting  cycle
Publication, 12-page PDF

Conflict minerals — Consumer and industrial products
Industry insight, 2-page PDF

Conflict minerals — Energy and resources
Industry insight, 2-page PDF

Conflict minerals — Life sciences and health care
Industry insight, 2-page PDF

Conflict minerals — Technology, media and telecommunications
Industry insight, 2-page PDF

The documents listed below have not yet been updated to reflect the SEC’s May 2, 2014, stay of those portions of its conflict minerals rule that were found to be unconstitutional by the U.S. Court of Appeals for the District of Columbia Circuit on April 14, 2014. Under the ruling and the SEC stay, issuers are still required to file Form SD and, if applicable, a Conflict Minerals Report on or before the June 2, 2014, due date; but they are not required to identify any products as having "not been found to be DRC conflict free" or as "DRC conflict undeterminable." For additional information, see Deloitte’s May 16, 2014, Accounting Journal Entry.

Attachments

Heads Up — Navigating reporting requirements for form SD and conflict minerals reports
Publication, 16-page PDF

Heads Up — As good as gold? SEC issues final rule on conflict minerals
Publication, 12-page PDF

Conflict minerals — IPSA Considerations
Report, 2-page PDF

Conflict minerals — Frequently asked questions
Brochure, 28-page PDF

Conflict minerals — An overview of scope of services including IPSA for audit clients
Brochure, 4-page PDF

Conflict minerals — Services
Brochure, 2-page PDF

Conflict minerals — Aerospace and defense
Brochure, 9-page PDF

Conflict minerals — Automotive
Brochure, 9-page PDF

Conflict minerals — Oil and gas
Brochure, 9-page PDF

Conflict minerals — Process and industrial products
Brochure, 9-page PDF

Conflict minerals — Retail
Brochure, 9-page PDF

Conflict minerals — Technology, media and telecommunications
Brochure, 9-page PDF

As used in this document, "Deloitte" means Deloitte LLP and its subsidiaries. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

Advisory services team

  • Kristen Sullivan
    Partner
    ksullivan@deloitte.com
  • Donald Fields
    Director
    dfields@deloitte.com
  • Jeff Torstenson
    Director
    jtorstenson@deloitte.com

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