Conflict Minerals Certification

For more information on the open questions created by the new rules a briefing on the industry group lawsuit challenging the new rules and an update on state local and private conflict minerals initiatives please see our companion client alert.

Conflict minerals certification. For example tin extracted in canada russia or argentina is considered a conflict mineral by definition. The country of origin of the conflict minerals in those products if known. On august 22 2012 the securities and exchange commission sec adopted a new rule and form as mandated by section 1502 of the dodd frank wall street reform and consumer protection act dodd frank act to require companies to publicly disclose their use of conflict. Conflict minerals faqs and recent developments.

The term conflict minerals refers to the four mineral ores and their common derivatives including cassiterite tin columbite tantalite coltan wolframite tungsten and gold. Certificate of non use of conflict minerals to our valued customers worldwide as required by the conflict minerals provisions under the dodd frank wall street reform and consumer protection act of 2010 abracon corporation continues to work proactively with all of our qualified suppliers. And its subsidiaries including alloy fasteners have reviewed the requirements of the current conflict minerals legislation passed in may of 2010 and promulgated for adherence january 2013. In that case the company must describe the following in its conflict minerals report.

57 a conflict free minerals chain of custody product control certificate provides information on the evaluated sites processes and product groups from which such products may originate and references the conflict free minerals chain of custody verification used in the evaluation by a conflict free minerals accredited third party auditor. Conflict minerals resource center your guide to conflict minerals compliance source intelligence ropes gray and the sponsoring associations have partnered to raise awareness and provide education to help companies in the supply chain comply with the current sec conflict minerals regulations. Its products manufactured or contracted to be manufactured that are drc conflict undeterminable the facilities used to process the conflict minerals in those products if known. In the sec rule drc conflict free is defined as minerals that were extracted and did not directly or indirectly benefit armed groups in the covered countries.

Division of corporation finance conflict minerals disclosure a small entity compliance guide 1 introduction. Conflict minerals nuts and bolts.