GAO-21-531, CONFLICT MINERALS: 2020 Company SEC
United States Government Accountability OfficeReport to Congressional CommitteesJuly 2021CONFLICTMINERALS2020 Company SECFilings on MineralSources Were Similarto Those from PriorYearsGAO-21-531
July 2021CONFLICT MINERALS2020 Company SEC Filings on Mineral Sources WereSimilar to Those from Prior YearsHighlights of GAO-21-531, a report tocongressional committeesWhy GAO Did This StudyWhat GAO FoundThe United States has sought toimprove security in the DRC for over 2decades. However, according to theDepartment of State and the UnitedNations, conflict has persisted andcontributed to severe human rightsabuses and the displacement ofpeople. Armed groups continue toprofit from the mining and trade of“conflict minerals,” according to State.Provisions in the 2010 Dodd-FrankWall Street Reform and ConsumerProtection Act required, among otherthings, the SEC to promulgatedisclosure and reporting regulationsregarding the use of conflict mineralsfrom the DRC and adjoining countries.In 2012, the SEC adopted a conflictminerals disclosure rule requiringcompanies to file specializeddisclosure reports beginning in 2014and annually thereafter. The act alsoincluded a provision for GAO toassess, among other things, the SECregulations’ effectiveness in promotingpeace and security in the DRC andadjoining countries.The Securities and Exchange Commission (SEC) disclosure rule on conflictminerals broadly requires that certain companies submit a filing that describestheir efforts to determine the source of their conflict minerals—tin, tungsten,tantalum, and gold. As part of this process, these companies must conduct areasonable country-of-origin inquiry (RCOI). Depending on the determinationreached through this inquiry, some companies must then conduct due diligenceto further investigate the source of their minerals.This report examines how companiesresponded to the SEC conflict mineralsdisclosure rule when filing in 2020.GAO analyzed a generalizable sampleof 100 SEC filings; reviewed SECdocuments; and interviewed SECofficials and other stakeholders,including representatives from theprivate sector and nongovernmentalorganizations.View GAO-21-531. For more information,contact Kimberly M. Gianopoulos at (202) 5128612 or gianopoulosk@gao.gov.According to GAO’s analysis, companies’ RCOI determinations have notchanged significantly since 2015. In 2020, an estimated 58 percent of thecompanies that conducted an RCOI reported preliminary determinationsregarding whether the conflict minerals in their products may have come from theDemocratic Republic of the Congo (DRC) or adjoining countries (coveredcountries), as the figure shows. Of those companies, an estimated 42 percentreported that they had preliminarily determined that at least some of theirminerals may have originated in covered countries, and an estimated 16 percentdetermined that their minerals were not from a covered country.Source of Conflict Minerals in Products as Determined by Companies’ Reasonable Country-ofOrigin Inquiries, Reporting Years 2014–2020In 2020, an estimated 78 percent of the companies that conducted an RCOI wenton to conduct due diligence to further investigate the source of their minerals.After conducting due diligence, an estimated 44 percent of these companiesreported that they could not determine whether their minerals originated incovered countries. An estimated 38 percent of the companies reported that theirminerals may have originated in covered countries, and the remaining 18 percentdid not clearly report their due diligence determination.Most filings indicated that companies used standardized tools and programs toattempt to determine the source of their minerals, but filings and industry expertsnoted challenges relating to these tools and programs. For example, anestimated 96 percent of company filings indicated use of a supplier survey tocollect information, but many companies did not receive responses from all theirsuppliers, of which there could be hundreds in some companies’ supply chains.United States Government Accountability Office
ContentsLetter1BackgroundCompanies’ Filings Were Similar to Those in Previous Years, withMany Companies Reporting They Could Not Determine theSource of Their Conflict MineralsAgency Comments1222Appendix IObjectives, Scope, and Methodology25Appendix IISummary of the Securities and Exchange Commission’sConflict Minerals Rule Disclosure Process28GAO Contact and Staff Acknowledgments32Appendix IIIRelated GAO Products333FiguresFigure 1: The Democratic Republic of the Congo and AdjoiningCountries (Covered Countries)Figure 2: Timeline of Events Related to the Implementation of theSecurities and Exchange Commission (SEC) ConflictMinerals Disclosure Rule, 2010–2020Figure 3: Total Number of Companies Filing Conflict MineralsDisclosures, 2014–2020Figure 4: Source of Conflict Minerals in Products as Determinedby Companies’ Reasonable Country-of-Origin Inquiries(RCOI), Reporting Years 2014–2020Figure 5: Flowchart of Companies’ Determinations Regarding theSource of Their Conflict Minerals, as Reported in 2020Figure 6: Simplified Conflict Minerals Supply Chain and Programsand Tools That Companies Use to Determine the Sourceof Their Conflict MineralsFigure 7: Securities and Exchange Commission FlowchartSummary of the Conflict Minerals Disclosure RulePage i681113161830GAO-21-531 Conflict Minerals
AbbreviationsDodd-Frank ActDRCEDGARForm SDIPSAOECDRCOISECSEC disclosure ruleUN2010 Dodd-Frank Wall Street Reform andConsumer Protection ActDemocratic Republic of the CongoElectronic Data Gathering, Analysis, andRetrievalspecialized disclosure reportindependent private-sector auditOrganisation for Economic Co-operationand Developmentreasonable country-of-origin inquirySecurities and Exchange CommissionSEC conflict minerals disclosure ruleUnited NationsThis is a work of the U.S. government and is not subject to copyright protection in theUnited States. The published product may be reproduced and distributed in its entiretywithout further permission from GAO. However, because this work may containcopyrighted images or other material, permission from the copyright holder may benecessary if you wish to reproduce this material separately.Page iiGAO-21-531 Conflict Minerals
Letter441 G St. N.W.Washington, DC 20548July 12, 2021Congressional CommitteesOver the past 2 decades, the United States and the internationalcommunity have sought to improve security in the Democratic Republic ofthe Congo (DRC). However, according to the Department of State andthe United Nations (UN), conflict has persisted and contributed to severehuman rights abuses and the displacement of people. State also reportedthat armed groups from the eastern region of the DRC profit from themining and trade of “conflict minerals”—in particular, tin, tungsten,tantalum, and gold.The 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act 1(Dodd-Frank Act) addresses, among other things, trade in conflictminerals. 2 Section 1502 of the act required several U.S. agencies,including the Securities and Exchange Commission (SEC), to take certainactions to implement its conflict minerals provisions. 3 The act required theSEC to promulgate disclosure and reporting regulations regarding the useof conflict minerals from the DRC and adjoining countries (collectivelyreferred to as “covered countries” in this report). 4 In response, the SECadopted a conflict minerals disclosure rule (SEC disclosure rule) in1Pub.L. No. 111-203, § 1502, 124 Stat. 1376, 2213-18.2TheDodd-Frank Act defines conflict minerals as columbite-tantalite (coltan), cassiterite,gold, wolframite, or their derivatives, or any other mineral or its derivatives that theSecretary of State determines to be financing conflict in the DRC or an adjoining country.See Pub. L. No. 111-203, § 1502(e)(4). Columbite-tantalite, cassiterite, and wolframite arethe mineral ores from which tantalum, tin, and tungsten, respectively, are processed.3The act required State, in consultation with the U.S. Agency for InternationalDevelopment, to submit a conflict minerals strategy to the appropriate congressionalcommittees to address the linkages between human rights abuses, armed groups, miningof conflict minerals, and commercial products. Pub. L. No. 111-203, § 1502(c). The actalso requires the Department of Commerce to report, among other things, a list of allknown conflict minerals processing facilities worldwide. Pub. L. No. 111-203, § 1502(d).4The Dodd-Frank Act defines the term “adjoining country” as a country that shares aninternationally recognized border with the DRC. Pub. L. No. 111-203, § 1502(e)(1). Whenthe SEC issued its conflict minerals rule, such countries included Angola, Burundi, CentralAfrican Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, andZambia. For the purposes of the SEC disclosure rule, the SEC refers to these countries,along with the DRC itself, as “covered countries.”Page 1GAO-21-531 Conflict Minerals
August 2012. 5 The SEC required companies to file specialized disclosurereports for the first time by June 2, 2014, and annually thereafter by May31. 6The SEC disclosure rule requires companies to (a) file a specializeddisclosure report known as a Form SD if they manufacture, or contract tohave manufactured, products that contain conflict minerals necessary tothe functionality or the production of those products, and (b) asapplicable, file a conflict minerals report. 7 The Form SD provides generalinstructions to companies for filing the conflict minerals disclosure andspecifies the information that each Form SD and conflict minerals reportmust include. In this report, we examine how companies responded to theSEC disclosure rule for conflict minerals when filing in 2020. 8To examine how companies responded to the SEC disclosure rule forconflict minerals when filing in 2020, 9 we downloaded disclosure reportsfrom the SEC’s publicly available Electronic Data Gathering, Analysis,and Retrieval (EDGAR) database. We determined that the EDGARdatabase was sufficiently reliable for identifying the universe of Form SD577Fed. Reg. 56,274 (Sept. 12, 2012) (codified at 17 C.F.R. § 240.13p-1).6Thefirst filing date was set for June 2, 2014, because May 31, 2014 occurred on aweekend. As explained in the SEC adopting release published in the Federal Register, ifthe deadline for filing the conflict minerals disclosure report occurs on a weekend, or aholiday on which SEC is not open for business, then the deadline shall be the nextbusiness day.7Asadopted, the final rule applies to any issuer that files reports with the SEC underSection 13(a) or Section 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§78m(a) and 78o(d)) and uses conflict minerals that are necessary to the functionality orproduction of a product manufactured or contracted by that issuer to be manufactured. Forthe purposes of our report, we refer to those issuers affected by the rule as “companies.”8TheDodd-Frank Act also included a provision for us to report on, among other things, theeffectiveness of the SEC rule in promoting peace and security in the DRC and adjoiningcountries. Pub. L. No. 111-203, § 1502(d), as amended by the GAO Mandates RevisionAct, Pub. L. No. 114-301, § 3, 130 Stat. 1514 (2016). This provision, as amended,requires us to report annually from 2012 through 2020, with additional reports in 2022 and2024. This report contributes to our body of work in response to these reportingrequirements in Section 1502 of the Dodd-Frank Act. To date, we have issued 12 reportsin response to these requirements. For a complete list of our previous work in this area,see the Related GAO Products page at the end of this report.9Conflictminerals disclosures filed with the SEC in a given year contain information aboutconflict minerals used in the previous year. For example, for this report we revieweddisclosures that companies filed with the SEC in 2020 about conflict minerals used in2019. All years cited in this report are calendar years, unless otherwise noted.Page 2GAO-21-531 Conflict Minerals
filings. To verify the completeness and accuracy of the EDGAR database,we reviewed relevant documentation, interviewed knowledgeable SECstaff, and reviewed prior GAO reports on internal controls related to theSEC’s data systems.We randomly sampled 100 Forms SD out of a total of 1,057 submitted tocreate estimates generalizable to the population of all companies thatfiled in response to the SEC disclosure rule in 2020. 10 We selected thissample size to achieve a margin of error of no more than plus or minus 10percentage points at the 95 percent confidence level, which applies to allour estimates. We reviewed the Dodd-Frank Act and the requirements ofthe SEC disclosure rule to develop a data collection instrument thatguided our analysis of the Form SD filings. We also interviewed anongeneralizable selection of stakeholders—including representativesfrom the private sector and nongovernmental organizations—to obtainadditional perspectives on meeting disclosure requirements. Seeappendix I for more information on our objectives, scope, andmethodology.We conducted this performance audit from October 2020 to July 2021 inaccordance with generally accepted government auditing standards.Those standards require that we plan and perform the audit to obtainsufficient, appropriate evidence to provide a reasonable basis for ourfindings and conclusions based on our audit objectives. We believe thatthe evidence obtained provides a reasonable basis for our findings andconclusions based on our audit objectives.BackgroundHistory of Conflict and theRole of Conflict MineralMining in the DRC and theRegionThe DRC is a vast, mineral-rich nation with an estimated population ofmore than 85 million people and an area that is roughly one-quarter thesize of the United States, according to the UN. Since gaining itsindependence from Belgium in 1960, the DRC has undergone politicalupheaval and armed conflict. From 1998 to 2003, the DRC and eightother African countries fought in what some have called “Africa’s WorldWar,” which resulted in the death of an estimated 5 million people in theDRC, according to State. In 1999, the UN deployed a peacekeepingmission to the DRC, and since then the United States and theinternational community have sought to improve security in the country.10Two companies submitted both a Form SD and an amended Form SD. In those cases,we excluded the original Forms SD and used the amended forms.Page 3GAO-21-531 Conflict Minerals
However, according to the UN, eastern DRC continues to be plagued byviolence—including numerous cases of sexual violence—that is oftenperpetrated against civilians by nonstate armed groups and somemembers of the Congolese national military and police.In 2019, the UN reported that state and nonstate armed groups, as wellas criminal networks, continued to tax or control mining activities ineastern DRC. 11 Armed groups use revenue from the illegal taxation andsale of conflict minerals to survive and to purchase arms and ammunition.The UN also reported that armed groups traffic minerals to neighboringcountries, including Burundi, Rwanda, and Uganda. Some of the nonstatearmed groups continue to grow, sometimes recruiting from and expandingto neighboring countries, according to the UN.Uses of Conflict MineralsSEC Disclosure Rule forConflict Minerals and SECStaff GuidanceVarious industries, particularly in manufacturing, use the four conflictminerals—tin, tungsten, tantalum, and gold—in a variety of products. Forexample: Tin is used to solder metal pieces and is found in food packaging,steel coatings on automobile parts, and some plastics. Tungsten is used in automobile manufacturing, drill bits, cutting tools,and other industrial manufacturing tools and is the primary componentof light bulb filaments. Most tantalum is used to manufacture capacitors that enable energystorage in electronic products, such as cell phones and computers, orto produce alloy additives used in turbines in jet engines. Gold is used as money reserves, in jewelry, and by the electronicsindustry, including in cell phones and laptops.In August 2012, the SEC adopted its disclosure rule for conflict mineralsin response to Section 1502(b) of the Dodd-Frank Act. 12 In its adoptingrelease for the rule, the SEC noted that Congress sought to accomplishthe goal of helping to end the human rights abuses that the DRC conflictcaused, by using the act’s disclosure requirements to increase publicawareness of the sources of companies’ conflict minerals and promote11United Nations Security Council, Midterm Report of the Group of Experts on theDemocratic Republic of the Congo, S/2019/974 (December 2019).1277Fed. Reg. 56,274.Page 4GAO-21-531 Conflict Minerals
the exercise of due diligence on conflict mineral supply chains. 13According to the SEC, Congress also sought to promote peace andsecurity and viewed reducing the use of conflict minerals as a way todecrease funding for armed groups and thereby put pressure on them toend the conflict. The map in figure 1 shows the countries covered by theSEC disclosure rule.1377Fed. Reg. 56,274. According to the SEC, when the SEC proposes or adopts a set ofrules, those rules are published in a document called a “proposing release” or “adoptingrelease.”Page 5GAO-21-531 Conflict Minerals
Figure 1: The Democratic Republic of the Congo and Adjoining Countries (Covered Countries)Note: The term “adjoining country” is defined in Section 1502(e)(1) of the 2010 Dodd-Frank WallStreet Reform and Consumer Protection Act as a country that shares an internationally recognizedborder with the Democratic Republic of the Congo (DRC), which included Angola, Burundi, CentralPage 6GAO-21-531 Conflict Minerals
African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia,at the time that the Securities and Exchange Commission (SEC) issued its conflict mineralsdisclosure rule. Pub. L. No. 111-203, § 1502(e)(1), 124 Stat. 1376, 2217. For the purposes of theconflict minerals disclosure rule, the SEC refers to these countries adjoining the DRC, along with theDRC itself, as “covered countries.”The SEC disclosure rule addresses the four conflict minerals named inthe Dodd-Frank Act originating from the covered countries. The rulerequires companies to (a) file a specialized disclosure report, Form SD, ifthey manufacture, or contract to have manufactured, products thatcontain conflict minerals necessary to the functionality or the productionof those products, and (b) file an additional conflict minerals report, ifapplicable. The Form SD provides general instructions to companiessubmitting a filing and specifies the information that a Form SD and aconflict minerals report must include. The conflict minerals report must befiled if a company after exercising due diligence has reason to believe itsconflict minerals may have come from covered countries and may not befrom scrap or recycled sources (for more information, see app. II).The rule outlines a process for companies to follow, as applicable, tocomply with the rule. The process broadly requires a company to1. determine whether it manufactures, or contracts to be manufactured,products with “necessary” conflict minerals;2. conduct a reasonable country-of-origin inquiry (RCOI) concerning theorigin of those conflict minerals; and3. exercise due diligence, if appropriate, to determine the source andchain of custody of those conflict minerals, adhering to a nationally orinternationally recognized due diligence framework, if such aframework is available for these necessary conflict minerals. 14In response to Section 1502(b) of the Dodd-Frank Act, the rule requirescompanies to file a conflict minerals report after performing the threesteps outlined above, if necessary. The timeline in figure 2 shows eventsrelated to the implementation of the SEC disclosure rule.14A company is required to perform due diligence on source and chain of custody andprovide a description of the measures it took to exercise due diligence if, after completingan RCOI, it knows or has reason to believe that its conflict minerals may have originatedin the covered countries and may not have been from scrap or recycled sources.Page 7GAO-21-531 Conflict Minerals
Figure 2: Timeline of Events Related to the Implementation of the Securities andExchange Commission (SEC) Conflict Minerals Disclosure Rule, 2010–2020aDodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), Pub. L. No. 111203, § 1502, 124 Stat. 1376, 2213-18.77 Fed. Reg. 56,274 (Sept. 12, 2012) (codified at 17 C.F.R. § 240.13p-1).bIn October 2012, stakeholders filed a lawsuit against the SEC regarding, among other things,whether SEC’s interpretations of certain key terms are consistent with congressional intent. Nat’lAss’n of Mfrs. v. SEC, 956 F. Supp. 2d 43 (D.D.C. July 23, 2013).cNat’l Ass’n of Mfrs. v. SEC, 748 F.3d 359 (D.C. Cir. Apr. 14, 2014).dNat’l Ass’n of Mfrs. v. SEC, No. 13-cv-635 (D.D.C. Apr. 3, 2017).ePage 8GAO-21-531 Conflict Minerals
2014 SEC Staff GuidanceFollowing an appellate court decision that found that a portion of thedisclosure required by the SEC violated the First Amendment, 15 SEC staffissued guidance in April 2014. This guidance indicated that, pendingfurther action by the SEC or a court, companies required to file a conflictminerals report would not have to identify their products as “DRC conflictundeterminable,” “not found to be ‘DRC conflict free,’” or “DRC conflictfree.” 16 According to the 2014 SEC staff guidance, companies are notrequired to obtain an independent private-sector audit (IPSA) unless theychoose to disclose that their products are “DRC conflict free” in a conflictminerals report. 172017 SEC Staff GuidanceIn April 2017, after the final judgment in the case, 18 the SEC staff issuedrevised guidance indicating that, because of uncertainty about how theSEC commissioners would resolve issues related to the court ruling, thestaff had determined that it would not recommend enforcement action tothe commission if companies did not report on specified disclosure15According to SEC staff, the U.S. Court of Appeals in April 2014 rejected challenges tothe bulk of the SEC conflict minerals rule. However, the court held that Section 1502 of theDodd-Frank Act and the rule violated the First Amendment to the extent that they requiredregulated entities to report to the SEC and to state on their website that any of theirproducts “have not been found to be DRC conflict free.” Nat’l Ass’n of Mfrs. v. SEC, 748F.3d 359 (D.C. Cir. Apr. 14, 2014).16See Keith F. Higgins, Director, SEC Division of Corporation Finance, Statement on theEffect of the Recent Court of Appeals Decision on the Conflict Minerals Rule (Apr. 29,2014). According to SEC staff, the April 2014 guidance is still in effect.17Under the SEC disclosure rule, an IPSA expresses an opinion or conclusion as towhether the design of the issuing company’s due diligence measures conforms in allmaterial respects with the criteria set forth in the nationally or internationally recognizeddue diligence framework the company used. The IPSA also expresses an opinion orconclusion on whether the description of those measures the company performed as setforth in its conflict minerals report is consistent with the due diligence process thecompany undertook.18The final judgment set aside the SEC disclosure rule “to the extent that the Statute andRule require regulated entities to report to the [Securities and Exchange] Commission andstate on their websites that any of their products have not been found to be ‘DRC conflictfree.’” Nat’l Ass’n of Mfrs. v. SEC, No. 13-cv-635 (D.D.C. Apr. 3, 2017). The District Courtalso remanded the case to the SEC.Page 9GAO-21-531 Conflict Minerals
requirements for due diligence. 19 However, SEC staff told us that the2017 guidance is not binding on the commission, which could initiateenforcement action if companies do not report on their due diligence inaccordance with the rule. The SEC Chairman released a statement in2018 confirming that SEC staff statements are nonbinding and do notcreate enforceable legal rights or obligations of the commission. Thestatement clarifies that there is a distinction between the SEC staff’sviews and the commission’s rules and regulations. 20 According to SECstaff, the Chairman’s statement was a general statement regarding staffviews and was not specific to staff statements regarding the conflictminerals rule. According to SEC staff, the 2017 guidance is temporary butstill in effect, pending the commission’s review of the rule. As of May2021, review of the rule was on the SEC’s long-term regulatory agenda,which means, according to SEC staff, that any action would likely not takeplace within the next 12 months.2020 Conflict MineralsReportsIn 2020, 1,057 companies filed conflict minerals disclosure reports withthe SEC. The number of disclosure reports that companies filed in 2020was fewer than the 1,083 filed in 2019 and the 1,117 filed in 2018. 21 This19The updated guidance specifically stated that “in light of the uncertainty regarding howthe [Securities and Exchange] Commission will resolve those issues [raised by the Court’sdecision] and related issues raised by commenters, the SEC’s Division of CorporationFinance [SEC staff] has determined that it will not recommend enforcement action to theCommission if companies, including those that are subject to paragraph (c) of Item 1.01 ofForm SD, only file disclosure under the provisions of paragraphs (a) and (b) of Item 1.01of Form SD.” The statement noted that it “is subject to any further action that may betaken by the Commission, expresses the Division’s position on enforcement action only,and does not express any legal conclusion on the rule.” See SEC Division of CorporationFinance, Updated Statement on the Effect of the Court of Appeals Decision on the ConflictMinerals Rule (Apr. 7, 2017).20See Jay Clayton, SEC Chairman, Statement Regarding SEC Staff Views (Sept. 13,2018).21See GAO, Conflict Minerals: Actions Needed to Assess Progress Addressing ArmedGroups’ Exploitation of Minerals, GAO-20-595 (Washington, D.C.: Sept. 14, 2020); andConflict Minerals: 2018 Company Reports on Mineral Sources Were Similar in Numberand Content to Those Filed in the Prior 2 Years, GAO-19-607 (Washington, D.C.: Sept. 9,2019).Page 10GAO-21-531 Conflict Minerals
trend reflects a continued decrease in the number of companies that havefiled disclosure reports since 2014 (see fig. 3). 22Figure 3: Total Number of Companies Filing Conflict Minerals Disclosures, 2014–2020We analyzed a generalizable sample of companies’ 2020 filings andfound that most companies reported the specific conflict minerals used intheir products. An estimated 71 percent of companies reported using tin;57 percent, tungsten; 57 percent, tantalum; and 64 percent, gold—percentages similar to those reported in 2019 and 2018. 23 An estimated22According to SEC officials, this decrease may be attributable to a variety of factors, suchas mergers and acquisitions among companies and changes in business practices bycompanies that previously filed disclosures. For example, companies that manufacturedifferent products that do not require the use of conflict minerals, or companies usingdifferent materials as a substitute for conflict minerals, are no longer required to file aconflict minerals disclosure.23Ourgeneralizable sample of 100 filings for 2014–2020 resulted in confidence intervalsof no more than plus or minus 10 percent, at the 95 percent confidence level. When wecompare estimates across these years and call them “similar in number,” we mean thatthe difference between the numbers is not statistically significant at the 95 percentconfidence level. For our analyses of 2019 and 2018 filings, respectively, seeGAO-20-595 and GAO-19-607.Page 11GAO-21-531 Conflict Minerals
93 percent of companies filed as domestic companies, while 7 percentfiled as foreign companies. 24Companies’ FilingsWere Similar toThose in PreviousYears, with ManyCompanies ReportingThey Could NotDetermine the Sourceof Their ConflictMineralsCompanies’ ReportedReasonable Country-ofOrigin InquiryDeterminations Have NotChanged Significantlysince 2015As previously mentioned, to comply with the disclosure rule, companiesmust conduct a reasonable country-of-origin inquiry (RCOI) topreliminarily determine whether any of the conflict minerals used in theirproducts may have originated in any of the covered countries or may notbe from recycled or scrap sources. We found that an estimated 99percent of companies that submitted conflict minerals filings in 2020reported that they had conducted an RCOI. This percentage is similar towhat we found for filings submitted in 2019 and 2018. 25We found that the percentage of companies that reported determinationsregarding the origins of their minerals following their RCOI increasedsignificantly from 2014 to 2015 and has not changed significantly since2015 (see fig. 4). Specifically, in 2020, an estimated 58 percent ofcompanies reported preliminary determinations regarding the source oftheir conflict minerals. This percentage is similar to what our analysisfound for filings submitted from 2015 through 2019, and higher than the30 percent of companies that we found reported these determinations in2014.24In 2019, an estimated 84 percent of companies filed as domestic and an estimated 16percent filed as foreign. In 2018, an estimated 85 percent of companies filed as domesticand an estimated 15 percent filed as foreign.25SeeGAO-20-595 and GAO-19-607.Page 12GAO-21-531 Conflict Minerals
Figure 4: Source of Conflict Minerals in Products as Determined by Companies’ Reasonable Country-of-Origin Inquiries(RCOI), Reporting Years 2014–2020Note: Companies reported determinations from 2014 through 2020 in response to
Conflict minerals disclosures filed with the SEC in a given year contain information about conflict minerals used in the previous year. For example, for this report we reviewed disclosures that companies filed with the SEC in 2020 about conflict minerals used in 2019. All years cited in this report are
Conflict Minerals and Resource Extraction: Dodd-Frank, SEC Regulations, and Legal Challenges Congressional Research Service 1 Introduction Congressional hearings, news reports over the past several years, and even the 2006 film Blood Diamond have brought increased attention to the mining and selling of conflict minerals. Generally defined, conflict minerals are “minerals mined in conditions .
Section 1 – Conflict Minerals Disclosure Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit Conflict Minerals Disclosure A copy of Apple Inc.’s (“Apple’s”) Conflict Minerals Report for the reporting period January 1, 2019 to December 31, 2019 is provided as
sian minerals. All minerals, however, can be classified into two main groups—silicate minerals and nonsilicate minerals—based on the chemical compositions of the minerals. Silicate Minerals A mineral that contains a combination of silicon, Si, and oxy-gen, O, is a silicate mineral. The mineral quartz has only silicon and oxygen atoms.
Functional vs Dysfunctional Conflict Functional Conflict- Conflict that supports the goals of the group and improves its performance Dysfunctional Conflict- Conflict that hinders group performance Task Conflict- Conflicts over content and goals of the work Relationship conflict- Conflict based on interpersonal relationships Process Conflict .
for conflict analysis. 2.1 Core analytical elements of conflict analysis . Violent conflict is about politics, power, contestation between actors and the . about conflict, see the GSDRC Topic Guide on Conflict . 13. Table 1: Guiding questions for conflict analysis . at conflict causes in Kenya in 2000. Actors fight over issues [, and .
Silicate Minerals Silicate minerals make up 96% of the earth’s crust. Contains atoms of Silicon (Si) and Oxygen (O). Silicate minerals are generally shinny therefore most are found in jewelry. Non-Silicate Minerals Non-silicate minerals only make up 4% of the earth’s crust. However, these minerals are used most widely in
2. some are composed of nonmineral matter a. obsidian, pumice and coal iii. composition and structure of minerals a. nearly 4,000 minerals b. elements 1. basic building blocks of minerals 2. 112 are known, 92 are naturally occurring 3. some minerals are made entirely of one atom 4. most elements are not stable, and thus most minerals are a
EMS to the ISO 14001 standard. Results Findings were graded as follows: OK - Item meets ISO 14001 and/or other requirements including the JLab EH&S Manual and SOPs. Noted on Corrective Action Request forms (CARs) only in particularly significant cases. Observations - Items which meet the intent of the requirements, but with minor inconsistencies. Noted on CARs, but no response required .
