Dodd-Frank Conflict Minerals

In August 2012, the Securities and Exchange Commission (SEC) approved a new rule known as the Conflict Minerals Rule. It requires publicly traded companies that use so-called "conflict minerals" — tantalum, tin, tungsten, and gold — in their products to make public disclosure of the origin of those minerals as part of their regular financial disclosures to the SEC.

The Rule applies directly to public companies in many industries — technology, aerospace, automotive, and consumer goods, to name a few. The Rule is intended to encourage these companies to strengthen their controls over how and where they obtain those minerals, thereby reducing the funding of armed groups responsible for extreme violence in the Democratic Republic of Congo and adjoining countries.

In April 2014, a federal court struck down portions of the Rule but left other parts intact. This Conflict Minerals training course explains compliance obligations in light of the April 2014 court ruling.

Non-compliance with the Conflict Minerals Rule can lead to severe consequences for a company, as well as its officers and employees. 

The topics covered in the course include:

• Overview of the Conflict Minerals Rule
• Compliance process
• Does the Rule apply?
• Conducting a "reasonable country of origin inquiry" (RCOI)
• Due diligence
• Conflict Minerals Report
• Costs of non-compliance