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On Question of Whether They Use Conflict Minerals, 90 Percent of Companies Shrug

ConflictGold Wall Street Journal  are, however, spending a lot of money to try to figure it out—a Journal regulations If, based on this inquiry, the company learns or has reason to believe that it has conflict minerals that originated in the DRC or adjoining countries, it must submit a Conflict Minerals Report to the SEC. Even if the inquiry reveals that the company did not utilize conflict minerals from the relevant areas, it must disclose this determination and briefly describe how it came to this conclusion. The report would also need to describe the measures the company took in order to exercise due diligence on the source and chain of custody of its conflict minerals.

The DRC, the second largest country in Africa, has been wracked with a series of long-running civil conflicts, many of which have been financed through the sale of conflict minerals. Consequently, according to the final rule, the purpose of the measure is to help "end the human rights abuses in the DRC caused by the conflict" through inhibiting "the ability of armed groups ... to fund their activities by exploiting the trade in conflict minerals." Because of this, the measure was well received by human rights groups such as the Enough Project and World Vision
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"Here’s how its products ended up at Tazreen anyway: Wal-Mart hired a megasupplier called Success Apparel to fill an order for shorts. Success hired another company, Simco, to carry out the work. Simco—without telling Success, much less Wal-Mart—sub-contracted 7 percent of the order to Tazreen’s parent company, the Tuba Group, which then assigned it to Tazreen. Two other sub- (or sub-sub-sub-) contractors also placed Wal-Mart orders at Tazreen, also without telling the company," the Huffington Post said. 

Wall Street Journal Journal
  • 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. 
  • The country of origin of the conflict minerals in those products, if known. 
  • The efforts to determine the mine or location of origin with the greatest possible specificity. 
  • The steps it has taken or will take, if any, since the end of the period covered in its most recent Conflict Minerals Report to mitigate the risk that its necessary conflict minerals benefit armed groups, including any steps to improve due diligence.
WSJ article compiled