Dodd-Frank Act

To eliminate “conflict minerals” Section 1502 of the Dodd-Frank Act was enacted, effective from 2013.

Conflict minerals: Au (Gold), Sn (Tin), W (Tungsten), and Ta (Tantalum)

What is Section 1502 of the Dodd-Frank Act?

Enforced on

Adopted in August 2012, enforced in 2013

  • Obligation to disclose the inclusion of conflict minerals in annual reports filed with the U.S. Securities and Exchange Commission (SEC)
  • Clearly specify the countermeasures implemented on the company’s website
    Reporting companies are required to “request the upstream company to conduct a survey and get a report on the results.”
    Since investigations can be extremely difficult, the validity of the investigation process is highly questionable.

Corporate Response

Compliance with CSR procurement practices

  • The law does not prohibit the use of conflict minerals; however, it requires companies to report the presence of conflict minerals. Moreover, the number of companies saying that they“cannot purchase tinwares of unknown origin.” is growing
    (Conflict FreePromotion
  • More and more companies are adopting conflict-minerals-free solders and plated products as a minimum requirement to increase the companies' corporate value, strengthen competitiveness, and maintain their supply chains.

Mandatory Reporting to the SEC