Dodd-Frank Wall Street Reform and Consumer Protection Act

Last updated: 5 December 2023

Implemented by the Securities and Exchange Commission (SEC), the Dodd-Frank Act was enacted in July 2010 to improve accountability and transparency of US listed companies and contained specialised disclosure provisions for responsible sourcing of minerals.
Section 1502 specifically deals with specific minerals designated as "conflict minerals" – i.e. tin, tantalum and tungsten, their ores, and gold. The law requires persons to disclose whether any conflict minerals “necessary to the functionality or production of a product” originated in the Democratic Republic of the Congo or an adjoining country. If originating from this area, such persons must provide a Conflict Minerals Report – audited by an independent private auditor – describing due diligence measures taken (e.g., facilities used to produce the conflict minerals, country of origin, and chain of custody of said minerals). In 2013, the SEC adopted Conflict Minerals rules for Section 1502. While the original rule stated that companies are required to label products as “not found to be DRC conflict free,” the D.C. Circuit Court struck down this provision. Following this decision, the reporting and due diligence requirements of the SEC's Section 1502 rules remain in effect, although there is no longer any labelling requirement.
Section 1503 requires mine operators to disclose violations, orders, and citations received from the Mine Safety and Health Administration. In 2011, the SEC adopted Mine Safety Disclosure rules for Section 1503.

Section 1504 requires mining companies to disclose payments made to a government, which will be made available online. In 2012, the SEC adopted rules for Section 1504.

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