October 21, 2014 · 27 Tishrei

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Legislative Summary
Information on the Dodd-Frank Wall Street Reform Act

On July 25th, 2010 the Dodd-Frank Wall Street Reform Act was signed into law by President Obama. The bill included a provision that requires companies which report to the Securities and Exchanges Commission and manufacture products that contain the 3Ts and gold to trace and disclose whether these minerals originated in Congo or a neighboring country. If a company finds that minerals used in their products originated in Congo or one of it neighboring countries they then must report on the measures they have taken to exercise due diligence in ensuring their supply chain does not either directly or indirectly fund armed groups controlling mines in eastern Congo.

Until now, companies have relied upon assurances from their suppliers that they do not purchase conflict minerals, without independent verification. With the Dodd-Frank law, the burden of proof shifts: now companies must find out where their suppliers actually source from. Most importantly, companies need to provide independent verification of these steps through an independent private sector audit of their reporting.

These provisions specifically only require companies to trace and audit their supply chains, but do not establish either a certification requirement or penalties for companies that source from conflict areas.



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