The Dodd-Frank Act, passed by Congress in 2010, directed the Securities and Exchange Commission (the “SEC”) to issue rules requiring certain SEC reporting companies to disclose their use of conflict minerals (including tantalum, tin, gold or tungsten) if those minerals are “necessary to the functionality or production of a product” manufactured by those companies.

The SEC adopted Rule 13p-1, which is now known as the Conflict Minerals Rule (the “Rule”). The intent of the Rule is to reduce a significant source of funding for armed groups that are committing human rights abuses and contributing to the conflict in the Democratic Republic of Congo and its adjacent countries. Although private companies are not directly subject to the Rule, to the extent that they are part of a public company’s supply chain, they will need to follow many of the same compliance procedures as public companies.

Does this apply to my company?

A company is considered to be “contracting to manufacture” a product if it has some actual influence over the manufacturing of that product. This determination is based on facts and circumstances, taking into account the degree of influence a company exercises over the product’s manufacturing. A company is not be deemed to have influence over the manufacturing if it merely: Affixes its brand, marks, logo, or label to a generic product manufactured by a third party. Services, maintains, or repairs a product manufactured by a third party. Specifies or negotiates contractual terms with a manufacturer that do not directly relate to the manufacturing of the product. The requirements apply equally to domestic and foreign issuers.

Company Listings

The following are links to member and nonmember companies’ conflict minerals policies and statements issued in connection with the Rule. By clicking on a company name, you will be taken to such company’s website or pdf.
These links are provided for your convenience only. NAED has no control over the contents of those sites or resources, and accepts no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third party websites linked to NAED’s website (the “Website”), you do so entirely at your own risk and subject to the terms and conditions of use for such websites.

**By accessing the links above, you agree to our terms and conditions.**