CONFLICT 

MINERALS

Stakeholder Options 

for Responsible 

Sourcing Are 

Expanding, but More 

Information on 

Smelters Is Needed 

Report to Congressional Committees

June 2014

GAO-14-575

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-575, a report to 

congressional committees

June 2014

CONFLICT MINERALS

Stakeholder Options for Responsible Sourcing Are 

Expanding, but More Information on Smelters Is 

Needed 

Why GAO Did This Study

Armed groups in eastern DRC 

continue to commit severe human 

rights abuses and profit from the 

exploitation of minerals, according to 

reports from the United Nations. 

Congress included a provision in the 

2010 Dodd-Frank Wall Street Reform 

and Consumer Protection Act to 

address the trade in “conflict 

minerals”—tin, tantalum, tungsten, and 

gold. Section 1502 of the Act directed

several U.S. agencies to report or 

focus on issues related to conflict 

minerals. 

This report examines, among other 

things, (1) the extent to which relevant 

U.S. agencies have undertaken

activities related to responsible 

sourcing of conflict minerals and (2) 

what is known about the status of, and 

information provided by, stakeholder 

initiatives focused on responsible 

sourcing of conflict minerals from the 

DRC and adjoining countries. GAO 

reviewed and analyzed documents and 

data covering 2003 through 2014. We

interviewed representatives from State, 

USAID, SEC, Commerce, 

nongovernmental organizations, 

industry, and international 

organizations who are cognizant of 

conflict minerals issues.

What GAO Recommends

GAO recommends that the Secretary 

of Commerce provide Congress a plan 

that outlines the steps, with associated 

timeframes, to develop and report the 

required information about smelters 

and refiners of conflict minerals 

worldwide. Commerce concurred with 

GAO’s recommendation and noted that 

it will submit a listing of all known 

conflict minerals processing facilities 

worldwide to Congress by September 

1, 2014.

What GAO Found

Since the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act)

was passed in 2010, relevant U.S. agencies have undertaken various activities 

related to responsible sourcing of conflict minerals from the Democratic Republic 

of the Congo (DRC) and adjoining countries. In response to the Act, the 

Department of State (State) and the U.S. Agency for International Development 

(USAID) developed a strategy in 2011 to address the linkages among human 

rights abuses, armed groups, and the mining of conflict minerals and are 

implementing various strategy objectives. The Securities and Exchange 

Commission (SEC) issued a rule in 2012 requiring certain companies to disclose

the source and chain of custody of necessary conflict minerals in their products. 

However, the Department of Commerce (Commerce) has not yet compiled a list 

of all conflict minerals processing facilities—smelters and refiners—known 

worldwide, required by January 2013 by the Act. Commerce cited difficulties with, 

for example, tracking conflict minerals operations but told GAO that it had 

completed outreach efforts with the majority of stakeholders. Commerce did not 

have a plan of action, with associated time frames, for developing and reporting

on the list of conflict minerals processing facilities worldwide. Standard practices 

in program and project management include, among other things, developing a 

plan to execute specific projects needed to obtain defined results within a specific 

time frame. An action plan with timeframes could better position Commerce to 

report on the status of its efforts to produce a final list to Congress and to hold its 

personnel accountable for completing activities.

Over the past several years, a number of stakeholders—foreign governments, 

multilateral organizations, and industry associations, among others—have 

expanded, or made plans to expand, initiatives focused on responsible sourcing 

of conflict minerals in the DRC and adjoining countries. These stakeholder 

initiatives, such as in-region tracing of conflict minerals and development of 

guidance documents and audit protocols, have grown to include new mine sites, 

countries, and smelters. For example, the Conflict-Free Smelter Program, an

industry-led effort, has expanded from 26 smelters certified as conflict-free in 

2013 to 85 smelters as of April 25, 2014 (see table). New stakeholder initiatives 

are also underway or planned in the region, including the first responsible 

sourcing initiative in the Congo-Brazzaville. Some initiatives have yielded publicly 

available information, including data on production of conflict-free minerals and 

export data. For example, one stakeholder has reported production data for tin, 

tungsten, and tantalum from three provinces in the DRC and in Rwanda. 

Number of Smelters and Refiners in the Conflict-Free Smelter Program as of April 25, 2014

Mineral

Number of smelters/refiners

certified as compliant

Number of smelters/refiners

working toward certification Total

Tantalum 28 1 29

Tin 13 14 27

Tungsten 1 8 9

Gold 43 2 45

Total 85 25 110

Source: Conflict-Free Sourcing Initiative data, GAO (analysis). View GAO-14-575. For more information, 

contact Kimberly M. Gianopoulos at (202) 512-

8612 or gianopoulosk@gao.gov.
Page i GAO-14-575 Conflict Minerals

Letter 1

Background 5

U.S. Agencies Have Taken Actions Related to Responsible 

Sourcing of Conflict Minerals, but Commerce Has Not Yet 

Fulfilled Its Requirements 13

Stakeholder Initiatives Are Expanding and Provide Some 

Information on Sourcing of Conflict Minerals 21

Little Additional Information on Rate of Sexual Violence in Eastern 

DRC and Adjoining Countries since July 2013 31

Conclusions 35

Recommendation for Executive Action 36

Agency and Third Party Comments and Our Evaluation 36

Appendix I Objectives, Scope, and Methodology 40

Appendix II State Department Map of Armed Groups Present at Mine Sites in the 

Democratic Republic of the Congo 43

Appendix III SEC Flowchart Summary of the Disclosure Process for the Final 

Conflict Minerals Rule 45

Appendix IV Sample Data from the ITRI Supply Chain Initiative 48

Appendix V Conflict Mineral Production and Export Data as Reported by the 

DRC and Rwandan Governments 52

Appendix VI Conflict Minerals Data from the International Trade Centre Data 

on Global Conflict Mineral Imports 56

Appendix VII Comments from the Department of Commerce 65

Contents
Page ii GAO-14-575 Conflict Minerals

Appendix VIII GAO Contacts and Staff Acknowledgments 67

Tables

Table 1: Number of Smelters and Refiners in the Conflict-Free 

Smelter Program as of April 25, 2014 23

Table 2: Production of Minerals from Maniema Covered by iTSCi 

for Q1 and Q2 of 2013, in Metric Tons 48

Table 3: Sales of Minerals from Maniema Covered by iTSCi for Q1 

and Q2 of 2013, in Thousands of U.S. Dollars 49

Table 4: Production of Minerals from South Kivu Covered by iTSCi 

for Q4 of 2012 through Q2 of 2013, in Metric Tons 49

Table 5: Sales of Minerals from South Kivu Covered by iTSCi for 

Q4 of 2012 through Q2 of 2013, in Thousands of U.S. 

Dollars 49

Table 6: Production of Minerals from Katanga Covered by iTSCi 

for Q2 of 2011 through Q2 of 2013, in Metric Tons 50

Table 7: Sales of Minerals from Katanga Covered by iTSCi for Q2 

of 2011 through Q2 of 2013, in Thousands of U.S. Dollars 50

Table 8: Production of Minerals from Rwanda Covered by iTSCi 

for Q2 of 2011 through Q2 of 2013, in Metric Tons 51

Table 9: Sales of Minerals from Rwanda Covered by iTSCi for Q2 

of 2011 through Q2 of 2013, in Thousands of U.S. Dollars 51

Table 10: Total Volume of Tin Production and Export from DRC 

for 2003-2012, in Metric Tons 52

Table 11: Total Volume of Tantalum Production and Export from 

DRC for 2003-2012, in Metric Tons 53

Table 12: Total Volume of Tungsten Production and Export from 

DRC for 2003-2012, in Metric Tons 53

Table 13: Total Volume of Gold Production and Export from DRC 

for 2003-2012, in Metric Tons 54

Table 14: Total Volume of Tin, Tantalum, and Tungsten Exports 

from Rwanda January-August 2013, in Metric Tons 54

Table 15: Total Value of Tin, Tantalum, and Tungsten Exports 

from Rwanda January-August 2013, in Thousands of U.S. 

Dollars 55

Table 16: ITC Estimates of Exports of Conflict Minerals from the 

Democratic Republic of the Congo for Fiscal Years 2009-

2013, in Metric Tons 56
Page iii GAO-14-575 Conflict Minerals

Table 17: ITC Estimates of Export Value of Conflict Minerals from 

the DRC for F Fiscal Years 2009-2013, in Thousands of 

U.S. Dollars 57

Table 18: ITC Estimates of Exports of Conflict Minerals from 

Angola for Fiscal Years 2009-2012, in Metric Tons 57

Table 19: ITC Estimates of Export Value of Conflict Minerals from 

Angola for Fiscal Years 2009-2013, in Thousands of U.S. 

Dollars 58

Table 20: ITC Estimates of Exports of Conflict Minerals from 

Burundi for Fiscal Years 2009-2012, in Metric Tons 58

Table 21: ITC Estimates of Export Value of Conflict Minerals from 

Burundi for Fiscal Years 2009-2013, in Thousands of U.S. 

Dollars 59

Table 22: ITC Estimates of Exports of Conflict Minerals from 

Central African Republic for Fiscal Years 2009-2012, in 

Metric Tons 59

Table 23: ITC Estimates of Export Value of Conflict Minerals from 

Central African Republic for Fiscal Years 2009-2013, in 

Thousands of U.S. Dollars 60

Table 24: ITC Estimates of Exports of Conflict Minerals from 

Rwanda for Fiscal Years 2009-2012, in Metric Tons 60

Table 25: ITC Estimates of Export Value of Conflict Minerals from 

Rwanda for Fiscal Years 2009-2013, in Thousands of 

U.S. Dollars 61

Table 26: ITC Estimates of Export of Conflict Minerals from 

Tanzania for Fiscal Years 2009-2012, in Metric Tons 61

Table 27: ITC Estimates of Export Value of Conflict Minerals from 

Tanzania for Fiscal Years 2009-2013, in Thousands of 

U.S. Dollars 62

Table 28: ITC Estimates of Exports of Conflict Minerals from 

Uganda for Fiscal Years 2009-2012, in Metric Tons 62

Table 29: ITC Estimates of Export Value of Conflict Minerals from 

Uganda for Fiscal Years 2009-2013, in Thousands of U.S. 

Dollars 63

Table 30: ITC Estimates of Exports of Conflict Minerals from 

Zambia for Fiscal Years 2009-2012, in Metric Tons 63

Table 31: ITC Estimates of Export Value of Conflict Minerals from 

Zambia for Fiscal Years 2009-2013, in Thousands of U.S. 

Dollars 64
Page iv GAO-14-575 Conflict Minerals

Figures

Figure 1: Map of the Democratic Republic of the Congo with 

Provinces and Adjoining Countries 6

Figure 2: Simplified Conflict Minerals Supply Chain 11

Figure 3: Timeline of the Starting Dates of Stakeholder-led 

Initiatives from 2008 to June 2014 22

Figure 4: Timeline of Population-Based Surveys Estimating the 

Rate of Sexual Violence in Eastern DRC, Rwanda, 

Uganda, and Burundi 33

Figure 5: State Department Map of the Presence of Armed 

Groups at Mine Sites in the Democratic Republic of the 

Congo, as of February 2014 44

Figure 6: SEC Flowchart Summary of Conflict Minerals Rule 46
Page v GAO-14-575 Conflict Minerals

Abbreviations

BGR German Federal Institute for Geosciences and Natural

Resources

CFSI Conflict-Free Sourcing Initiative

CFTI Conflict-Free Tin Initiative

Commerce United States Department of Commerce

DHS Demographic and Health Survey

Dodd-Frank Act Dodd-Frank Wall Street Reform and Consumer

Protection Act

DRC Democratic Republic of the Congo

EICC Electronic Industry Citizenship Coalition 

GeSI Global e-Sustainability Initiative

EU European Union

ICGLR International Conference on the Great Lakes Region

iTSCi ITRI Tin Supply Chain Initiative

LBMA London Bullion Market Association

M-23 March 23 Movement

MONUSCO UN Organization Stabilization Mission in the

Democratic Republic of the Congo

NGO nongovernmental organization

OECD Organisation for Economic Co-operation and

Development

PPA Public-Private Alliance for Responsible Minerals Trade

SEC Securities and Exchange Commission

State United States Department of State

UN United Nations

USAID United States Agency for International Development

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

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Page 1 GAO-14-575 Conflict Minerals

441 G St. N.W.

Washington, DC 20548

June 26, 2014

Congressional Committees

Over the past decade, the United States and the international community 

have sought to improve security in the Democratic Republic of the Congo 

(DRC), the site of one of the world’s worst humanitarian crises. The 

International Rescue Committee has previously estimated that since 

1998, more than 5.4 million people have died in the DRC as a result of 

this crisis, which has also destabilized the minerals-rich eastern part of 

the country, created insecurity, displaced thousands of people, and 

perpetuated a cycle of poverty. As we previously reported, illegal armed 

groups and some units of the Congolese national military have committed 

severe human rights abuses and mass killings and profited from the 

illegal exploitation of minerals originating in eastern DRC, particularly in 

the provinces of North Kivu and South Kivu.1 Despite some success in 

efforts to improve security in eastern DRC—notably, the November 2013 

defeat of M-23, an illegal armed group,2 as well as campaigns against 

other illegal armed groups—the UN reported that as of December 2013, 

illegal armed groups in eastern DRC continued to pose a threat to 

security, to be responsible for human rights abuses and displacements of 

people, and to derive funding from the illicit production, trade, and 

smuggling of conflict minerals.3

Citing the continuing urgency of the humanitarian situation and the need 

to take action, in July 2010, Congress included in the Dodd-Frank Wall 

Street Reform and Consumer Protection Act (hereafter referred to as the 

 1

GAO, The Democratic Republic of the Congo: U.S. Agencies Should Take Further 

Actions to Contribute to the Effective Regulation and Control of the Minerals Trade in 

Eastern Democratic Republic of the Congo, GAO-10-1030 (Washington, D.C.: Sept. 30, 

2010).

2

M-23 was created in May 2012 in eastern DRC and surrendered to DRC forces in 

November 2013.

3

United Nations Security Council, “Letter dated 12 December 2013 from the Group of 

Experts on the Democratic Republic of the Congo addressed to the Chair of the Security 

Council Committee established pursuant to resolution 1533 (2004) concerning the 

Democratic Republic of the Congo,” Annex to “Letter dated 22 January 2014 from the 

Coordinator of the Group of Experts on the Democratic Republic of the Congo addressed 

to the President of the Security Council,” S/2014/42 (Jan. 23, 2014).
Page 2 GAO-14-575 Conflict Minerals

Act or Dodd-Frank Act) provisions pertaining to trade involving conflict 

minerals—tantalum, tin, tungsten, and gold.4 Section 1502 of the Act 

directed several U.S. agencies—the Securities and Exchange 

Commission (SEC), the Department of State (State), the U.S. Agency for 

International Development (USAID), and the Department of Commerce 

(Commerce)—to take certain actions to implement the Act’s conflict 

minerals provisions, including provisions related to responsible sourcing 

of conflict minerals from the DRC and the adjoining countries.5 The Act 

specifically directed the SEC to promulgate a rule, which SEC issued in 

August 2012, that requires certain issuers to disclose annually to SEC 

whether any of such minerals are necessary to the functionality or 

production of products manufactured, or contracted to be manufactured, 

by the issuer originated in the DRC or adjoining country and if so, to 

provide an additional report.6

To address our mandates, since July 2011 we have issued several 

reports on topics ranging from the rate of sexual violence in the DRC and 

adjoining countries to SEC’s rule and initiatives focused on responsible 

The Act also mandated GAO to report, 

beginning in 2012 and annually thereafter, on the effectiveness of the 

SEC rule in promoting peace and security in the DRC and adjoining 

countries, and annually, beginning in 2011, on the rate of sexual violence 

in war-torn areas of DRC and adjoining countries, among other things.

 4

The Dodd-Frank Act defines conflict minerals as columbite-tantalite (coltan), cassiterite, 

gold, wolframite, or their derivatives, or any other mineral or its derivatives that are 

determined by the Secretary of State to be financing conflict in the DRC or an adjoining 

country. See Pub. L. No. 111-203 §1502, (e)(4). Columbite-tantalite (coltan), cassiterite, 

and wolframite are the ores from which tantalum, tin, and tungsten, respectively, are 

processed.

5

In this report, the countries adjoining DRC—Angola, Burundi, Central African Republic, 

the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia—are 

often termed “Dodd-Frank affected countries.”

6

Under the rule, SEC-reporting companies with “necessary” conflict minerals in products 

they manufactured or contracted to have manufactured must conduct a “reasonable 

country of origin inquiry” to determine whether their conflict minerals originated in the DRC 

or adjoining countries. If none of their conflict minerals originated in that region, they must 

file a Form SD to disclose the reasonable country of origin inquiry they conducted and the 

results. If any of a company’s “necessary” conflict minerals originated in the DRC or 

adjoining countries, the company must exercise due diligence on the source and chain of 

custody of its conflict minerals and also file a Conflict Minerals Report.
Page 3 GAO-14-575 Conflict Minerals

sourcing of minerals.7 Because the first SEC-required disclosures of 

manufacturers’ use of conflict minerals were not due to SEC until June 

2014, and because sufficient time must elapse to allow the rule’s full 

impact to materialize, we have not yet addressed the effectiveness of 

SEC’s conflict minerals rule as required under the legislation. Moreover, 

our ability to report on the rule’s effectiveness will depend on the 

availability of information on stakeholder initiatives to, for example, 

monitor, ensure, or report on responsible sourcing of conflict minerals 

from the DRC and adjoining countries.8

1. the extent to which relevant U.S. agencies have taken actions related 

to the responsible sourcing of conflict minerals;

Consequently, in this report, we 

examine

2. what is known about the status of, and any information provided by, 

stakeholder initiatives focused on responsible sourcing of conflict 

minerals from the DRC and adjoining countries; and

3. any new information about the rate of sexual violence in eastern DRC 

and three adjoining countries—Burundi, Rwanda, and Uganda—that 

has become available since we issued our 2013 report.9

To address our first and second objectives, we reviewed and analyzed 

available data covering 2003 through 2014 on conflict minerals from the 

DRC and adjoining countries and from responsible sourcing initiatives, as 

well as reports and other documents from relevant U.S. agencies, foreign 

governments, multilateral organizations, nongovernmental organizations 

(NGOs), and industry associations. Because the data were not used to 

 7

GAO, The Democratic Republic of the Congo: Information on the Rate of Sexual 

Violence in War-Torn Eastern DRC and Adjoining Countries, GAO-11-702 (Washington, 

D.C.: July 13, 2011); Conflict Minerals Disclosure Rule: SEC’s Actions and StakeholderDeveloped Initiatives, GAO-12-763 (Washington, D.C.: July 16, 2012); SEC Conflict 

Minerals Rule: Information on Responsible Sourcing and Companies Affected, 

GAO-13-689 (Washington, D.C.: July 18, 2013). In our 2012 report, we addressed, for 

example, a congressional mandate that asked us to describe any issues that the SEC 

encountered in promulgating a conflict minerals disclosure rule. In our 2013 report, we 

addressed, for example, a mandate that asked us to describe information that may be 

publicly available about entities that use conflict minerals but are not required to report to 

SEC under the rule.

8

Stakeholders include relevant U.S. agencies; foreign governments; multilateral 

organizations, such as the Organization for Economic Cooperation and Development 

(OECD); nongovernmental organizations (NGOs); and industry associations.

9

GAO-13-689.
Page 4 GAO-14-575 Conflict Minerals

support findings, conclusions, or recommendations, we did not assess 

their reliability. We also interviewed State, USAID, Commerce, and SEC 

officials as well as stakeholder representatives from international 

organizations, NGOs, and industry associations who are cognizant of 

conflict minerals issues. We selected these stakeholders based on their 

expertise on responsible sourcing issues, because they represented a 

range of perspectives on conflict minerals, and because we had 

established contacts with these entities on our last review.

10 In addition, 

some of the stakeholders we talked to have been working on the ground 

in the DRC. The stakeholders we spoke with constitute a 

nongeneralizable sample, and the information we gathered from them 

cannot be used to infer views of other stakeholders cognizant of conflict 

minerals issues. To address our third objective, we reviewed and 

analyzed relevant documents and interviewed representatives from State, 

USAID, various UN agencies, relevant NGOs, and researchers to identify 

any new data on sexual violence. Specifically, we followed up with 

officials from those groups we interviewed for our prior review on sexual 

violence rates in eastern DRC and adjoining countries.11

We conducted this performance audit from September 2013 to June 2014 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

We also 

conducted Internet literature searches to identify new academic articles 

containing any additional information available since our 2013 report. See 

appendix I for a complete description of our scope and methodology.

 10GAO-13-689. 

11GAO-13-689.
Page 5 GAO-14-575 Conflict Minerals

The DRC is a vast, mineral-rich nation with an estimated population of 

about 75 million people and an area that is roughly one-quarter the size of 

the United States, according to the UN. The map in figure 1 shows the 

DRC’s provinces and adjoining countries.

Background

Brief History of Conflict in 

the DRC and the Region
Page 6 GAO-14-575 Conflict Minerals

Figure 1: Map of the Democratic Republic of the Congo with Provinces and Adjoining Countries
Page 7 GAO-14-575 Conflict Minerals

Since its independence in 1960, the DRC has undergone political 

upheaval, including a civil war, according to State. In particular, the 

eastern DRC has continued to be plagued by violence often perpetrated 

by illegal armed groups and some members of the Congolese national 

military against civilians. In November 2012, M-23, an illegal armed 

group, occupied the city of Goma and other cities in eastern DRC and 

clashed with the Congolese national army. During this time, the UN 

reported numerous cases of sexual violence against civilians, including 

women and children, that were perpetrated by armed groups and some 

members of the Congolese national military.12

Prior to the defeat of M-23, in February 2013, the 11 countries in the 

region adopted the “Peace, Security and Cooperation Framework for the 

Democratic Republic of the Congo and the Region.”

Although M-23 eventually 

withdrew from the cities, the group’s presence in the region continued. In 

December 2012, the Ugandan president began to broker peace talks, 

known as the Kampala Dialogue, between M-23 and the DRC 

government, aimed at reaching a final and principled agreement that 

ensured the disarmament and demobilization of M-23 and accountability 

for human rights abuses. The M-23 was defeated in November 2013 by 

the Congolese national military with support from UN forces. In December 

2013, the former M-23 and the DRC each signed individual declarations 

that, among other things, set out the conditions for the disarmament, 

demobilization, and reintegration of M23 into Congolese society and 

called for those responsible for war crimes and crimes against humanity 

to be held accountable.

13

 12The Office of the High Commissioner for Human Rights and the United Nations 

Organization Stabilization Mission in the Democratic Republic of the Congo (MONUSCO) 

issued a report in May 2013 on mass rapes and other violations of human rights 

committed in Minova, a town in South Kivu, and surrounding areas in November 2012. 

The report documented 135 cases of sexual violence perpetrated by elements of the 

Congolese national army in and around the town of Minova as units retreated from the 

front lines.

Some of the 

13The eleven signatories to the framework were Angola, Burundi, the Central Africa 

Republic, the DRC, the Republic of the Congo (also known Congo-Brazzaville), Rwanda, 

South Africa, South Sudan, Tanzania, Uganda, and Zambia. The UN Secretary-General, 

the Chairperson of the African Union Commission, the Chairperson of the Southern 

African Development Community, and the Chairperson of the International Conference on 

the Great Lakes Region signed the agreement as witnesses. In January 2014, two 

additional countries, Kenya and Sudan, also signed the framework. According to the UN, 

the framework encompasses commitments at the national, regional and international 

levels to bring peace and stability to the eastern DRC and the region.
Page 8 GAO-14-575 Conflict Minerals

adjoining countries in the region have also experienced recent turmoil, 

which has led to flows of large numbers of refugees into the DRC in 

addition to internally displaced persons.14 The United Nations High 

Commissioner for Refugees (UNHCR) estimated, as of mid 2013, that 

there were close to 50,000 refugees from the Central African Republic, in 

addition to over 120,000 refugees from other countries, as well as around 

2.6 million internally displaced persons living in camps or with host 

families in the DRC.

Congress has focused on issues related to the DRC for almost a decade. 

In 2006, Congress passed the Democratic Republic of Congo Relief, 

Security, and Democracy Promotion Act of 2006,15

Provisions in the Dodd-Frank Act Related to Conflict Minerals in the DRC and 

Adjoining Countries

stating that U.S policy 

is to engage with governments working for peace and security throughout 

the DRC and hold accountable individuals, entities, and countries working 

to destabilize the government. In July 2010, Congress passed the DoddFrank Act, which included several provisions in section 1502 of the Act 

concerning conflict minerals in the DRC and adjoining countries. The Act 

directs State, USAID, SEC, and Commerce to take steps on matters 

related to the implementation of those provisions (see text box).

• Section 1502(a) states that “it is the sense of the Congress that the exploitation and 

trade of conflict minerals originating in the Democratic Republic of the Congo is 

helping to finance conflict characterized by extreme levels of violence in the eastern 

Democratic Republic of the Congo, particularly sexual- and gender-based violence, 

and contributing to an emergency humanitarian situation therein, warranting the 

provisions of section 13(p) of the Securities Exchange Act of 1934, as added by 

subsection (b).” 

• Section 1502(b) requires SEC, in consultation with State, to promulgate disclosure 

and reporting regulations regarding the use of conflict minerals from DRC and 

adjoining countries.

• Section 1502(c) requires State and USAID to develop, among other things, a 

strategy to address the linkages among human rights abuses, armed groups, the 

mining of conflict minerals, and commercial products. 

• Section 1502(d) requires that Commerce report, among other things, a listing of all 

known conflict minerals processing facilities worldwide.

Source: GAO analysis. | GAO-14-575

 14According to the UN, internally displaced persons are people who have not crossed an 

international border but have moved to a different region than the one they call home 

within their own country to escape war, persecution, or terror. 

15Pub. L. No. 109-456.

U.S. Government 

Response to Conflict in 

the DRC
Page 9 GAO-14-575 Conflict Minerals

In addition, in July 2013, the United States appointed the current Special 

Envoy for the Great Lakes Region and the DRC, whose office develops 

and leads the implementation of U.S. regional policy on cross-border 

security, political, economic and social issues. The Special Envoy leads 

U.S. efforts to support the implementation of the Peace, Security, and 

Cooperation Framework Agreement, including the development and

implementation of a comprehensive strategy to stop human suffering and 

violence in the region, by promoting political, economic, and social 

reconciliation.

In 1999, the UN Security Council authorized peacekeeping operations in 

the DRC, known as the UN Organization Mission in Democratic Republic 

of the Congo (MONUC).16

The international community has also responded to the conflict in the 

DRC and adjoining countries by appointing special envoys to the region. 

For example, in March 2013, the UN appointed a Special Envoy of the 

Secretary-General for the Great Lakes Region to support the 

implementation of the 11-nation Peace, Security and Cooperation 

Framework for the Democratic Republic of the Congo and the Region.

MONUC’s mission included achieving a 

ceasefire and protecting civilians and other nonmilitary personnel from 

threats of physical violence. In 2010, MONUC was replaced by the UN 

Organization Stabilization Mission in the Democratic Republic of the 

Congo (MONUSCO), whose priorities also include protecting civilians and 

stabilizing the country.

17

 16Initially, MONUC’s focus was on the ceasefire and disengagement of forces and 

maintenance of liaison with all parties involved with the civil war, but the operation 

expanded to include the effective protection of civilians, humanitarian personnel, and 

human rights defenders under imminent threat of physical violence. 

In June 2013, the UN also appointed the current Special Representative 

of the Secretary-General for the Democratic Republic of the Congo and 

Head of MONUSCO. Both the European Union and African Union also 

have appointed representatives for the Great Lakes Region. To address 

imminent threats to peace and security, the UN Security Council also 

authorized the deployment of a force intervention brigade within the 

current peacekeeping operations in the DRC on March 28, 2013. The 

17According to the UN, the envoy’s key tasks include undertaking good offices to 

strengthen the relations between the signatories of the framework, revitalizing existing 

accords and coordinating the international engagement. 

International Response to 

Conflict in the DRC
Page 10 GAO-14-575 Conflict Minerals

objectives of the new force based in North Kivu province are to neutralize 

armed groups, reduce the threat they pose to state authority and civilian 

security, and make space for stabilization activities.18

In addition, the European Union (EU) is exploring possible legislation 

related to conflict minerals and responsible sourcing.19 According to a 

European Commission release, in March 2014, the EU proposed a draft 

regulation setting up an EU system of self-certification for importers of tin, 

tantalum, tungsten, and gold for imports into the EU. The draft regulation 

indicated that the self-certification would align with the Organization for 

Economic Cooperation and Development’s (OECD) “OECD Due 

Diligence Guidance for Responsible Supply Chains of Minerals from 

Conflict-Affected and High-Risk Areas,” which includes a five-step 

framework for risk-based due diligence in the supply chain.20 According to 

the release, the regulation gives EU importers an opportunity to deepen 

ongoing efforts to ensure clean supply chains when trading legitimately 

with operators in conflict-affected countries.

 18The mandate of the force intervention brigade was renewed by the UN Security Council 

until March 2015.

19Canada also has a proposed conflict minerals initiative. According to State, Canada’s 

Conflict Minerals Act was reintroduced for discussion in the Canadian parliament in April 

2014 and would require Canadian companies to exercise due diligence in respect of the 

exploitation and trading of designated conflict minerals originating in the Great Lakes 

Region of Africa. 

20The OECD due diligence guidance, which OECD adopted in 2011, includes 

supplements on tin, tantalum, tungsten, and gold. The framework’s five steps are (1) 

establishing strong company management systems, (2) identifying and assessing risk in 

the supply chain, (3) designing and implementing a strategy to respond to identified risks, 

(4) carrying out an independent third-party audit of supply chain due diligence at identified 

points in the supply chain, and (5) reporting on supply chain due diligence. Organization 

for Economic Cooperation and Development, OECD Due Diligence Guidance for 

Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: 

Second Edition, OECD Publishing (2013), accessed June 23, 2014,

http://dx.doi.org/10.1787/9789264185050-en.
Page 11 GAO-14-575 Conflict Minerals

Supply chains for companies using tin, tantalum, tungsten, and gold 

generally begin at the mine site, where ore is extracted from the ground 

with mechanized or artisanal mining techniques.21

Figure 2: Simplified Conflict Minerals Supply Chain

However, these supply 

chains can be complex and vary considerably, according to some industry 

association and company representatives. For example, as figure 2 

shows, in the “upstream” segment of the supply chain—that is, from mine 

to smelter—ore may be purchased by a local processor or trader and 

then by an exporter, who ships it to a smelter for refinement; in other 

cases, the ore may be sold directly to an exporter. The “downstream”

segments of conflict mineral supply chains—that is, from smelter to 

manufacturer—may vary as well, depending in part on the type of 

mineral. Figure 2 provides a simplified depiction of the supply chain for 

the four conflict minerals.

Smelters and refiners are considered the “choke points” in the supply 

chain, since a limited number of smelters and refiners process conflict 

minerals worldwide and the origin of the minerals after processing can be 

difficult to verify. Smelters primarily provide high-purity tin, tantalum, and 

tungsten directly to component parts manufacturers, although some sell 

high-purity metals through traders or exchanges. Gold refiners typically 

sell high-purity gold to banks for use as a store of value or to international 

exchanges where gold is bought and sold,22

 21Artisanal mining is a form of mining characterized by a lack of mechanization or capital 

investment.

although some refiners sell 

22According to a World Gold Council representative, in most cases refiners are paid a fee 

to refine gold and the transaction is conducted by the miner, the trader, and the bank.

Uses of Conflict Minerals

Various industries, particularly manufacturing 

industries, use the four conflict minerals in a 

wide variety of products. For example, tin is 

used to solder metal pieces and is also found 

in food packaging, in steel coatings on 

automobile parts, and in some plastics. Most 

tantalum is used to manufacture tantalum 

capacitors, which enable energy storage in 

electronic products such as cell phones and 

computers as well as used to produce alloy 

additives, which can be found in turbines in jet 

engines. Tungsten is used in automobile 

manufacturing, drill bits and cutting tools, and 

other industrial manufacturing tools and is the 

primary component of filaments in light bulbs. 

Gold is used as reserves and in jewelry and is 

also used by the electronics industry.

Source: GAO-12-763. | GAO-14-575

Conflict Minerals Supply 

Chains
Page 12 GAO-14-575 Conflict Minerals

gold directly to manufacturers; banks and traders may also sell gold to 

manufacturers, including jewelry and component parts manufacturers. 

Component parts manufacturers use the refined tin, tantalum, tungsten, 

or gold to construct individual parts—such as capacitors, engine parts, or 

clasps for necklaces—that they sell to original equipment manufacturers. 

The original equipment manufacturers complete the final assembly of a 

product and sell the final product to the consumer.

Various stakeholders—including governments, industry associations, 

international organizations, and international and local NGOs working in 

the Great Lakes Region—operate or support initiatives to promote and 

exercise responsible sourcing of conflict minerals. Stakeholder-developed 

initiatives—which include the development of guidance documents, audit 

protocols, and sourcing practices—support efforts by companies reporting 

to SEC under the rule to (1) conduct due diligence of their conflict 

minerals supply chain, (2) identify the source of conflict minerals within 

their supply chain, and (3) responsibly source conflict minerals. The 

initiatives can be divided into two categories: global or in-region.23

Most responsible sourcing initiatives follow OECD’s due-diligence 

guidance.24 The guidance is for use by any company potentially sourcing 

minerals or metals from conflict-affected and high-risk areas and, 

according to OECD, is one of the only international frameworks available 

to help companies meet their due diligence reporting requirements.

 23See GAO-12-763.

24Organization for Economic Cooperation and Development, OECD Due Diligence 

Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk 

Areas: Second Edition (Paris: November 2012).

Responsible Sourcing 

Initiatives

Global and In-Region Sourcing Initiatives 

Global sourcing initiatives may minimize the 

risk that minerals that have been exploited 

by illegal armed groups will enter the supply 

chain and may also support companies’ 

efforts to identify the source of the conflict 

minerals across the supply chain around the 

world. In-region sourcing initiatives may 

support responsible sourcing of conflict 

minerals from Central Africa and the 

identification of specific mines of origin for 

those minerals. Such initiatives in DRC and 

adjoining countries focus on tracing minerals 

from the mine to the mineral smelter or 

refiner by supporting a bagging and tagging 

program or some type of traceability 

scheme. 

Source: GAO | GAO-14-575
Page 13 GAO-14-575 Conflict Minerals

Since the Act was passed in 2010, State, USAID, SEC, and Commerce 

have undertaken activities related to implementation of the Act’s conflict 

minerals provisions, including activities related to responsible sourcing of 

such minerals from the DRC and adjoining countries. As required by the 

Act, State and USAID developed a strategy in 2011 aimed at addressing 

the linkages between human rights abuses, armed groups, the mining of 

conflict minerals, and commercial products and are implementing various 

objectives of the strategy. State also produced a map of mineral-rich 

areas under control of armed groups in the DRC. SEC issued its required 

conflict minerals rule in 2012. As of May 2014, Commerce had taken 

steps toward producing a list of all conflict minerals processing facilities 

worldwide, which the Act required by January 2013, but had not 

completed the task. Moreover, Commerce had not developed a plan of 

action with associated timeframes for how and when it expects to 

complete this effort and report to Congress. Standard practices in 

program and project management and execution include, among other 

things, developing a plan to execute specific projects needed to obtain 

defined results within a specific time frame.25 State, USAID, SEC, and 

Commerce also have engaged in activities involving stakeholder 

partnerships and outreach and have provided technical assistance to 

other governments related to activities focused on the responsible 

sourcing of conflict minerals.

The Act directed State, USAID, SEC, and Commerce to undertake 

various activities to implement its provisions related to conflict minerals. 

Since the Act was passed in 2010, the agencies have taken the following 

actions.

Responding to the Act, State and USAID developed a strategy in 2011 to 

address the linkages among human rights abuses, armed groups, the 

mining of conflict minerals, and commercial products. The Act required 

State and USAID to submit, by January 2011,26

 25The Project Management Institute, The Standard for Program Management (2013). 

a strategy to address the 

26The Act states that a strategy be submitted to Congress no later than 180 days after the 

enactment of the law.

U.S. Agencies Have 

Taken Actions 

Related to 

Responsible Sourcing 

of Conflict Minerals, 

but Commerce Has 

Not Yet Fulfilled Its 

Requirements

State, USAID, and SEC 

Have Addressed the Act’s 

Requirements, and 

Commerce Is Working 

toward Fulfilling Its 

Requirements

State and USAID Developed a 

Strategy, and State Produced 

a Conflict Minerals Map
Page 14 GAO-14-575 Conflict Minerals

linkages between human rights abuses, armed groups, mining of conflict 

minerals, and commercial products. The strategy document that State 

and USAID submitted to Congress in 2011 lists five objectives: (1) 

promote an appropriate role of security forces, (2) enhance civilian 

regulation of minerals trade in the DRC, (3) protect artisanal miners and 

local communities, (4) strengthen regional and international efforts, and 

(5) promote due diligence and responsible trade through public outreach. 

The strategy includes activities corresponding with each of these 

objectives—for example, building the capacity of civilian mining 

authorities in the DRC to certify mine sites, supporting the implementation 

and coordination of certification and traceability schemes, building the 

capacity of the ICGLR related to mineral audit mechanisms, and 

engaging with industries and civil society groups regarding supply chain 

due diligence efforts. State and USAID officials indicated that they have 

been implementing objectives of the strategy over the past few years. 

According to the U.S. Special Envoy for the Great Lakes Region and the 

DRC, the strategy remains relevant and accurate and State has used it in 

conjunction with other U.S. government agencies as a roadmap for efforts 

to help break the link between armed groups and conflict minerals.

In addition, in 2011, State developed a map of mineral-rich zones and 

areas under control of armed groups in the DRC and has subsequently 

published several updated maps, as required by the Act.27 The maps are 

focused on the exploitation of tin, tantalum, tungsten, and gold in the 

provinces of North and South Kivu and parts of Orientale, Maniema, and 

Katanga provinces. According to State, the most current map, which 

State published in February 2014, was based on data from surveys 

conducted in 2013 by the International Peace Information Service 

(IPIS)—an NGO— and on information from consultations with the DRC 

government, the UN Group of Experts, and MONUSCO (see app. II for 

the 2014 map).28

 27The Act requires that State should update its map every 180 days.

State reported that lack of complete or fully verifiable 

data makes it difficult to confirm the location of many mine sites, to 

establish which mine sites are active at any given time, and to 

comprehensively verify reports of armed groups or other entities that are 

28IPIS has also published a report that analyzes the information it collects and populates 

in its interactive map. See International Peace Information Service, Analysis of the 

Interactive Map of Artisanal Mining Areas in Eastern DR Congo, (Antwerp, Belgium: 

November 2013), accessed June 23, 2014, 

http://ipisresearch.be/mapping/webmapping/drcongo. 
Page 15 GAO-14-575 Conflict Minerals

either present at mines or have access to revenue streams emanating 

from them. State officials indicated that in the future the map may become 

digital rather than paper based.

As we previously reported,29 SEC issued its conflict minerals rule in 

August 2012.30 The Act required that SEC promulgate, by April 2011, 

disclosure and reporting regulations regarding the use of conflict minerals 

from the DRC and adjoining countries.31

 29GAO-13-689.

30In October 2012, the U.S. Chamber of Commerce, the National Association of 

Manufacturers, and the Business Roundtable filed a lawsuit against SEC challenging the 

final conflict minerals rule, making claims based on the Administrative Procedure Act, the 

Securities Exchange Act of 1934, and the First Amendment. In July 2013, the U.S. District 

Court for the District of Columbia denied the plaintiff’s claims on all counts. See National 

Association of Manufacturers v. SEC, 956 F. Supp. 2d 43 (D.D.C. 2013). In August 2013, 

the petitioners appealed the decision to the U.S. Court of Appeals for the District of 

Columbia Circuit, and on April 14, 2014, the appeals court upheld the District Court’s 

findings on all the petitioners’ claims except the First Amendment claims, concluding that 

section 13(p) of the Exchange Act and the final conflicts minerals rule violate the First 

Amendment “to the extent the statute and rule require regulated entities to report to the 

Commission and to state on their website that any of their products have ‘not been found 

to be DRC conflict free.’” National Association of Manufacturers, et al. v. SEC et al., No. 

13-5252 (D.C. Cir. April 14, 2014). In response to the appeals court’s findings, SEC staff, 

on April 29, 2014, issued a statement that it expects companies to file any reports required 

under Rule 13p-1 subject to any further action that may be taken either by the 

Commission or a court. The SEC staff’s statement contains guidance to companies, which 

provides, among other things, that no company is required to describe its products (1) as 

“DRC conflict free” (2) as having “not been found to be ‘DRC conflict free’,” or (3) as “DRC 

conflict undeterminable” in their reports. The guidance also states that a company may 

voluntarily elect to describe any of its products as “DRC conflict free” in its report if it had 

obtained an independent private sector audit as required by the rule. In addition, the 

guidance states that, pending further action, an independent private sector audit will not 

be required unless a company voluntarily elects to describe a product as “DRC conflict 

free” in its Conflict Minerals Report. On May 2, 2014, the SEC issued an order staying the 

effective date for compliance with the portions of Rule 13p-1 and Form SD subject to the 

appeals court’s First Amendment holding pending the completion of judicial review. On 

May 5, 2014, the plaintiffs filed a motion with the appeals court asking the court to stay the 

entire rule pending the completion of judicial review which the Commission opposed, and 

on May 2014, the appeals court denied the motion.

31Pub. L. No. 111-203, sec 1502(b). The Act required that a rule should be promulgated 

no later than 270 days after the law’s enactment. As we reported in 2012, SEC’s issuance 

of the rule encountered delays, including delays in developing, modifying, and finalizing 

the rule, as a result of several factors. See GAO-12-763. Also see appendix III for a 

flowchart summarizing the conflict minerals rule that SEC published when the rule was 

adopted in 2012.

SEC Issued Its Conflict 

Minerals Rule in 2012
Page 16 GAO-14-575 Conflict Minerals

SEC issued a “frequently asked questions” (FAQ) document in May 2013 

to address questions by companies that will have to report to SEC under 

the conflict minerals rule. SEC officials indicated that these FAQs 

included questions posed most often by companies regarding 

interpretation of the rule. In April 2014, SEC issued additional FAQs 

addressing questions that mostly pertained to the independent private 

sector audit of companies’ conflict minerals disclosure reports. According 

to an SEC official, these FAQs were based on interpretive questions 

asked by SEC-reporting companies and the audit community.

In January 2014, SEC made “Form SD,” a specialized disclosure form for 

reporting compliance with the conflict minerals rule, available for 

electronic filing. The form, originally published with the conflict minerals 

rule, provides general instructions to SEC-reporting companies for filing 

the conflict minerals disclosure and specifies the information that their 

conflict minerals reports must include. SEC-reporting companies were 

required to file under the rule for the first time by June 2, 2014, and 

annually thereafter on May 31.32 According to SEC officials, based on 

preliminary feedback they received, they anticipated that most SECreporting companies subject to the rule would be unable to determine 

whether or not their products qualified as “DRC conflict-free.”33

More than a year after the deadline required by the Act, Commerce has 

not yet fulfilled its mandate under section 1502 of the Act. Section 1502 

directed Commerce to report, among other things, a list of all known 

conflict minerals processing facilities worldwide to appropriate 

congressional committees annually starting no later than 30 months after 

 32The SEC rule indicates that if the deadline for filing the conflict mineral disclosure report 

occurs on a weekend, or on a holiday which the SEC is not open for business, then the 

deadline shall be the next business day.

33According to the rule, for a temporary period following the effective date of the rule—4 

years for smaller reporting companies or 2 years for all other reporting companies—if a 

company is unable to determine whether the minerals in its products originated in DRC or 

the adjoining countries or financed or benefited armed groups in those countries, then 

those products are considered “DRC conflict undeterminable” and no audit is required. 

According to SEC officials, as a result of the SEC’s partial stay order and the SEC staff’s 

statement, companies are not required to describe their products in their reports as “DRC 

conflict undeterminable” pending further action by the SEC or a court, and no audits are 

required unless a company voluntarily describes any of its products as “DRC conflict free”

in its Conflict Minerals Report. 

Commerce Has Taken Steps 

but Has Not Provided a List of 

Conflict Minerals Processing 

Facilities to Congress
Page 17 GAO-14-575 Conflict Minerals

the Act’s enactment—that is, by January 2013.34

Commerce officials said that they had encountered some challenges 

associated with gathering data on conflict minerals to help inform their 

outreach plan and required reporting. For example, according to the 

officials, conflict minerals and mining operations are difficult to track; 

because the equipment used to process conflict minerals can be moved 

easily, such operations can emerge in different locations. In addition, 

Commerce officials mentioned that some conflict minerals data may be 

inaccessible to the U.S. government because a large number of conflict 

As of May 2014, 

Commerce had not developed such a list or developed a plan of action, 

with associated time frames, for completing this requirement and 

reporting it to Congress. Standard practices in program and project 

management include developing, among other things, a program plan to 

execute specific projects needed to obtain defined programmatic results 

within a specific time frame. In January 2014, Commerce officials told us 

that they had identified entities that they hoped would help them identify 

publicly available information about conflict minerals and identify 

stakeholders who are knowledgeable about conflict minerals issues. 

Specifically, Commerce officials indicated that they had assembled a 

proposed and internal outreach plan, which includes meeting with 

stakeholders to discuss how these organizations have gathered 

information on conflict mineral smelters and identifies other efforts that 

Commerce can explore to develop the list of conflict minerals processing 

facilities. Commerce officials also indicated that they anticipated a 3- to 4-

month time frame for the proposed outreach efforts to talk to 

stakeholders. In May 2014, Commerce officials stated that they had 

completed discussions with the majority of the stakeholders identified in 

the outreach plan and have developed several preliminary lists of conflict 

minerals processing facilities, based on information they obtained from 

the stakeholders. However, Commerce officials stated that they did not 

have a timeframe for completing the final list for Congress.

 34The Act also requires Commerce to annually report (1) an assessment of the accuracy 

of the independent private sector audits and other due diligence processes required under 

section 1502 and (2) recommendations for the processes to carry out such audits, 

including ways to improve the accuracy of the audits and to establish standards of best 

practices. Commerce officials stated that it was unable to implement these aspects of the 

Act’s requirement because the SEC disclosure reports, which are needed for the 

assessment, were not due to SEC until June 2, 2014.
Page 18 GAO-14-575 Conflict Minerals

mineral smelters are in China.35

Some stakeholders that we contacted, including government and industry 

officials and representatives of the UN Group of Experts and an NGO, 

indicated that a comprehensive list of conflict minerals smelters and 

refiners—considered the “choke point” of the supply chain—would be 

very useful in the effort to ensure responsible sourcing of minerals in the 

DRC and adjoining countries. According to these stakeholders, such a list 

would enable companies that are subject to the SEC rule to maintain 

transparency regarding their supply chains, particularly in their 

communications with smelters, and would also provide companies the 

information they need for their SEC-required conflict minerals disclosure 

reports.

Having an action plan with associated 

timeframes could better position Commerce to report on the status of its 

efforts to compile a list of conflict minerals processing facilities worldwide 

and to hold its personnel accountable for completing its related activities.

U.S. government agencies have engaged in a variety of activities that 

involve partnerships and coordination with other stakeholders or outreach 

to stakeholders, and some agencies have provided technical assistance 

to stakeholders regarding responsible sourcing of conflict minerals. Some

agencies’ activities contribute to global and in-region responsible sourcing 

initiatives and some of the activities address the implementation of 

objectives outlined in the strategy to address the linkages between 

human rights abuses, armed groups, and the mining of conflict minerals.

Some U.S. agencies have partnered and coordinated with other 

stakeholders—other government agencies, industry, and civil society—

regarding issues related to responsible sourcing of conflict minerals. For 

example:

• State and USAID, both in headquarters and posts or missions 

overseas, and other U.S. agencies coordinate with one another on 

weekly or biweekly conference calls to discuss the progress of 

responsible sourcing efforts, provide updates on recent events, and 

collaborate on future events, according to State and USAID officials.

 35Our 2013 report identified 82 smelters and refiners of tin, tantalum, tungsten, and gold 

located in China, of the 278 smelters and refiners that we identified worldwide.

U.S. Agencies Have 

Engaged in Partnerships 

and Outreach and 

Provided Technical 

Assistance to 

Stakeholders

U.S. Agency Partnerships and 

Coordination Efforts
Page 19 GAO-14-575 Conflict Minerals

• USAID works in a collaborative and coordinated manner with State in 

Washington and regionally, using the 2011 U.S. strategy as a 

framework for the coordination, according to USAID officials. The 

officials indicated that funding also has been coordinated between the 

two agencies across the five objectives of the strategy and totals over 

$25 million, as of 2013.

• State and USAID coordinate with other stakeholders through the 

Public-Private Alliance for Responsible Minerals Trade (PPA) to fund 

and support organizations working on responsible sourcing efforts. 

Both State and USAID are on the PPA’s Governance Committee, 

which consists of participants from foreign governments, industry, and 

civil society.36

• USAID has partnered with the International Organization for Migration 

to help enhance civilian control of the DRC’s mineral trade through 

infrastructure improvements and institutional reforms, according to 

agency officials. The officials reported that with USAID funding, the 

organization will also establish pilot certification and traceability 

systems in and around the mineral trading centers and other areas of 

South and North Kivu.37

• USAID has partnered and coordinated with stakeholders in the DRC, 

according to agency officials. For example, the officials said that 

USAID is coordinating with the DRC government regarding various 

aspects of minerals trade, is involved in the multi-stakeholder Mining 

Thematic Group in the DRC, and facilitates the Eastern Congo Mining 

Coordination Team.

• On a multilateral level, both USAID and State participate in the OECD 

Responsible Sourcing Stakeholder Forums held every 6 months, 

according to USAID officials. This forum, coordinated by the ICGLR, 

OECD, and the UN Group of Experts, is a platform for governments, 

the private sector, international organizations, and civil society to 

share experiences with implementation of supply chain due diligence 

for responsible sourcing of minerals from conflict-affected and high-

 36According to USAID, it holds two of the four government positions on the Committee in 

addition to State and the ICGLR. There are four civil society and four private sector 

members of the Committee as well.

37According to an NGO report, the objective of mineral trading centers, or centre de 

negoce, is to provide a center where miners and traders can do business without 

interference from armed groups. The report notes that, at the same time, state agents can 

exert control and levy taxes, traders can receive the necessary paperwork, and miners 

can profit from a market environment in which they can negotiate better prices for their 

products.
Page 20 GAO-14-575 Conflict Minerals

risk areas. Both State and USAID officials have participated at times 

as facilitators of these forums.

• The current U.S. Special Envoy for the Great Lakes Region and the 

DRC has collaborated with other stakeholders, such as the UN 

Special Envoy for the Great Lakes, the African Union, and other 

multilateral and bilateral partners, to strengthen international 

coordination mechanisms on the crisis in the Great Lakes, according 

to State. These efforts have taken place under the Peace, Security, 

and Cooperation Framework Agreement for the DRC and the Region.

A couple of U.S. government agencies indicated that they have 

conducted outreach to various stakeholders to promote responsible 

sourcing of conflict minerals and to obtain information about conflict 

mineral sourcing and supply chains. For example, State and Commerce 

officials reported the following.

• State officials told us that State has engaged with foreign 

governments and industry associations regarding the Dodd-Frank Act 

requirements. According to these officials, State’s efforts have

included sending letters about section 1502 of the Act to foreign 

governments that are prominent in the conflict mineral supply chain as 

well as encouraging these governments and companies in those 

countries to support the aim of the legislation. In a November 2013 

briefing, the Deputy Assistant Secretary of State for Counter Threat 

Finance and Sanctions reported that he had travelled to Asia and 

Europe to talk with representatives from smelters and governments 

about responsible sourcing initiatives and encourage participation in 

such initiatives. State officials also indicated that they have facilitated 

outreach efforts for industry associations, such as the Conflict-Free 

Smelter Initiative (CFSI) and others, to help them secure meetings in 

Asian countries to discuss conflict free mining and smelting. 

According to the State officials, during the outreach some members 

from industry and industry associations expressed interest in talking to 

Commerce about smelters and support for responsible sourcing, 

according to State officials.

• Commerce officials stated that their proposed outreach plan identified 

entities that could enable them to develop the list of conflict mineral 

smelters and refiners required by the Act. According to these officials, 

they have conducted outreach to these entities, including government 

agencies, industry associations, international organizations, and 

NGOs.

Some U.S. agencies have provided technical assistance related to 

responsible sourcing of conflict minerals to various stakeholders. 

According to agency officials, these stakeholders have consisted primarily 

U.S. Agency Outreach Efforts

U.S. Agency Technical 

Assistance
Page 21 GAO-14-575 Conflict Minerals

of other governments, particularly in the Great Lakes Region. For 

example:

• State officials said that they had shared experiences and challenges 

related to implementing the Act with officials from the EU who were 

working on proposed conflict minerals legislation.

• SEC officials stated that they had discussed with EU officials issues 

that SEC considered when drafting the conflict minerals rule as well 

as questions about the rule that SEC received from industry.

• USAID officials stated that they had been working with the ICGLR in 

providing technical assistance on conflict minerals programs, 

particularly through the steering committee for ICGLR’s Regional 

Initiative against the Illegal Exploitation of Natural Resources.38

Specifically, according to USAID officials, USAID has been 

implementing a multiyear institutional capacity program in support of 

the ICGLR to build the overall strength of the Executive Secretariat as 

well as the ICGLR’s regional initiative. USAID officials said that the 

agency will soon begin implementing activities to support a third-party 

supply chain audit mechanism and an independent conflict minerals 

supply chain auditor.

Since we reported in July 2013,39 stakeholders have expanded existing 

initiatives and added new initiatives focused on responsible sourcing of 

conflict minerals in the DRC and adjoining countries, to include new mine 

sites, countries, and smelters. Some of these initiatives have yielded 

publically available information, including data on production of conflictfree minerals and export data, as well as reports on the progress and 

results of the initiatives. However, this information is limited in scope and 

thus may not provide a comprehensive description of the sourcing of 

conflict minerals from the DRC and adjoining countries.

 38The Regional Steering Committee, comprising technical experts from all ICGLR member 

states, has been charged with the steering of all activities within the initiative since 

September 2009. Its suggestions on policies and technical guidelines are to be approved 

at a later stage by the Regional Inter-Ministerial Committee as well as the ICGLR Summit. 

39GAO-13-689.

Stakeholder Initiatives 

Are Expanding and 

Provide Some 

Information on 

Sourcing of Conflict 

Minerals
Page 22 GAO-14-575 Conflict Minerals

Stakeholders have recently expanded, or made plans to expand, a 

number of existing global and in-region responsible sourcing initiatives; 

and two new initiatives are underway. Figure 3 shows the starting dates 

for existing, expanding, and new responsible sourcing initiatives. 

According to some stakeholders we interviewed, improvement in security 

in eastern DRC and industries’ growing awareness of responsible 

sourcing and the Act’s requirements may account for the expansion of 

responsible sourcing initiative.

Figure 3: Timeline of the Starting Dates of Stakeholder-led Initiatives from 2008 to June 2014

Stakeholders Have 

Expanded Existing 

Initiatives, and New 

Initiatives Are Underway
Page 23 GAO-14-575 Conflict Minerals

The following are examples of global responsible-sourcing initiatives that 

stakeholders have expanded since we reported in July 2013.40

Conflict-Free Sourcing Initiative

The Conflict-Free Sourcing Initiative (CFSI) has expanded in several 

aspects related to responsible sourcing.41 First, CFSI’s Conflict-Free 

Smelter Program has expanded the number of smelters it has certified as 

conflict free. The program is a voluntary one in which smelters undergo 

an independent third-party audit, in accordance with OECD’s due 

diligence guidelines, to verify the origin of minerals processed at their 

facilities. The number of smelters that the program has certified as 

conflict-free has expanded from 26 smelters in summer 2013 to 85 

smelters as of April 25, 2014 (see table 1). An additional 25 smelters are 

in the process of being certified, bringing the total number of smelters 

involved in the program to 110.42

Table 1: Number of Smelters and Refiners in the Conflict-Free Smelter Program as 

of April 25, 2014 

As of January 2014, the Conflict-Free 

Smelter Program has expanded to include smelters for tungsten in 

addition to the other three conflict minerals.

Mineral

Number of certified 

smelters/refiners

Number of smelters/refiners 

working toward certification Total

Tantalum 28 1 29

Tin 13 14 27

Tungsten 1 8 9

Gold 43 2 45

Total 85 25 110

Source: Conflict-Free Sourcing Initiative data, GAO (analysis). | GAO-14-575

 40GAO-13-689.

41CFSI was founded in 2008 by members of the Electronic Industry Citizenship Coalition 

(EICC) and the Global e-Sustainability Initiative (GeSI). According to EICC and GeSI, as 

of April 30, 2013, CFSI now includes EICC and GeSI activities and is an expanded 

initiative of the EICC and GeSI Extractives Working Group, which includes more 

stakeholders and a wider range of industry sectors supporting the sourcing of conflict-free 

minerals.

42The actual number of smelters and refiners of conflict minerals is unknown. However, in 

2013, we reported that the total number of smelters and refiners worldwide could be as 

high as 500. See GAO-13-689. 

Some Existing Global 

Initiatives Are Expanding
Page 24 GAO-14-575 Conflict Minerals

Second, according to CFSI representatives, through outreach to industry, 

CFSI has expanded its collaboration with companies involved with the 

conflict minerals supply chain. CFSI’s outreach includes twice-yearly 

workshops on conflict minerals issues that are open to all participants. 

According to CFSI, outreach such as these workshops bring together 

hundreds of representatives from industry, government, and civil society 

for updates, in-depth discussions, and guidance on best practices for 

responsible mineral sourcing.43

Third, in 2014, CFSI began offering its members information about the 

SEC-required “reasonable country of origin” data for conflict minerals, 

providing the most detailed information currently available about the 

source of conflict minerals for smelting and refining facilities that are 

validated through the Conflict-Free Smelter Program. According to CFSI, 

this information may be useful to companies as they prepare the conflict 

minerals disclosure reports required by the SEC rule and demonstrate 

conformance with the OECD due diligence guidelines.

CFSI officials stated that such outreach 

recently resulted in collaboration with the tungsten industry, which led to 

certification of the first conflict-free tungsten smelter in 2014.

Responsible Gold Program

In January 2012, the London Bullion Market Association (LBMA), which 

represents the global market for gold and silver, finalized and published 

its Responsible Gold Guidance to ensure that the gold refiners it accredits 

purchase only conflict-free gold.44

 43The World Bank defines “civil society” as referring to the wide array of nongovernmental 

and not-for-profit organizations that have a presence in public life, expressing the interests 

and values of their members or others, based on ethical, cultural, political, scientific, 

religious, or philanthropic considerations.

The refiners accredited by LBMA are 

required to complete an annual third-party audit to verify their compliance 

with the LBMA guidance, according to an LBMA official. As of March 

2014, of the 67 gold refiners that LBMA oversees, more than threequarters had successfully submitted their audits and received the 

Responsible Gold Certificate, according to the official. The representative 

stated that if a refiner does not submit a third-party audit by the end of 

44LBMA oversees the London Good Delivery List, a list of 67 accredited gold refiners that 

meet a specific standard for the quality of their refined gold and silver bars. According to 

LBMA representatives, most banks and exchanges will only contract with refiners on the 

Good Delivery List.
Page 25 GAO-14-575 Conflict Minerals

2014, the refiner will be removed from LBMA’s list of accredited refiners. 

An LBMA official said that the association also collaborates with other 

responsible sourcing stakeholders and global gold exchanges and works 

closely with OECD. For example, the official said that, working through 

OECD, LBMA has met with Chinese industry representatives to clarify the 

purpose and benefits of conducting due diligence audits of their refiners.

Responsible Jewellery Council Chain-of-Custody Certification 

Program

The Responsible Jewellery Council—a diamond and precious metals 

industry association—launched a chain-of-custody certification program in 

March 2012 to help its member companies identify and track conflict-free 

gold throughout their supply chains.45 The program’s requirements, which 

are aligned with the OECD Due Diligence Guidance for gold, include a 

third-party audit of each certified entity to ensure that its gold is conflictfree, according to the Responsible Jewellery Council. According to an 

official with the Responsible Jewellery Council, this certification can 

support companies’ compliance with the Dodd Frank Act. As of April 

2014, nine entities had been validated under the council’s certification 

program and more entities were in the process of being certified, 

according to the official.

46

The following are examples of in-region responsible sourcing initiatives 

that stakeholders have expanded, or made plans to expand, since we 

reported in July 2013.

 45The Responsible Jewellery Council launched its chain-of-custody program to also help 

its member companies identify and track the supply chains of other precious metals, such 

as platinum, palladium, and rhodium. Chain of custody refers to the paper trail that 

documents the sequence of entities with custody of minerals as they move through a 

supply chain.

46Officials of the Responsible Jewellery Council reported that the council has developed 

cross-recognition agreements with CFSI, LBMA, and the World Gold Council to reduce 

unnecessary duplicative audits for their member companies. For example, according to an 

LBMA official, once LBMA approves a third-party audit, verifying that a gold refiner is 

conflict-free, the association contacts CFSI to add the refiner to CFSI’s list of compliant 

smelters and refiners.

Some In-Region Initiatives 

Have Also Expanded
Page 26 GAO-14-575 Conflict Minerals

ITRI Tin Supply Chain Initiative

The ITRI Tin Supply Chain Initiative (iTSCi) recently announced that it is 

expanding its in-region operations. The initiative works with “upstream”

entities (i.e., companies involved in the conflict minerals supply chain 

from mine to smelter) in instituting the actions, structures, and processes 

necessary to conform with the OECD Due Diligence Guidance and helps 

relevant U.S. companies report on their due diligence efforts to the SEC 

as required by the Dodd-Frank Act.47

In February 2014, iTSCi announced that it was expanding its traceability 

program into a remote area in the northern region of the Maniema 

province of the DRC, and into the North Kivu province of the DRC. 

According to iTSCi, improved security in North Kivu, which has a history 

of armed conflict, accounts in part for the expansion into the province. An 

iTSCi official stated that the initiative is currently looking at options for 

extending into South Kivu. Additionally, in April 2014, iTSCi announced 

that the program had started operations in Burundi. According to iTSCi, 

there is presently little evidence of activity by nongovernment armed 

groups in Burundi, since there have been no reports that armed groups 

are controlling mine sites or transportation routes, extorting money or 

minerals, or illegally taxing the trade of minerals. iTSCi further reported 

that it may extend the program to Uganda and eventually to the entire 

Great Lakes Region. Also, an iTSCi official stated that the initiative had 

successfully piloted technology in Rwanda to collect and manage data on 

conflict minerals electronically, which would replace the current paperbased system and increase efficiency of data collection.

The assistance that iTSCi provides 

includes a system to trace bags of minerals from the mines to the 

exporter, due diligence audits of iTSCi’s member companies, and 

assessments of the political and security situations, which have been 

conducted at various mine sites in the DRC and Rwanda.

 47According to iTSCi, as of November 2013, the traceability program is used at more than 

850 mines in the South Kivu, Maniema, and Katanga provinces of the DRC and in 

Rwanda. Almost all in-region responsible sourcing initiatives—including Solutions for 

Hope and the Conflict-Free Tin Initiative—use iTSCi’s traceability system of tracking 

minerals from the mine to the exporter to ensure that their minerals are conflict-free. 
Page 27 GAO-14-575 Conflict Minerals

Solutions for Hope

Launched by Motorola Solutions and AVX in 2011, the Solutions for Hope 

tantalum program is a “closed-pipeline” initiative that traces the flow of 

tantalum from the mine to the end-use company.48

Conflict-Free Tin Initiative

In June 2013, 

Solutions for Hope reported that it had completed six shipments of 

tantalum, totaling more than 145 metric tons, from the Katanga province 

in the DRC. According to officials, in part because of improved security in 

the province, the initiative started sourcing tantalum from North Kivu in 

March 2014. Officials also noted that Solutions for Hope is exploring a 

closed pipeline system for gold in the DRC.

The Conflict-Free Tin Initiative (CFTI), a multistakeholder effort supported 

by the Netherlands government, is a closed-pipeline initiative, similar to 

Solutions for Hope, started in October 2012 for sourcing tin from the 

South Kivu province of the DRC. According to CFTI, the initiative has 

expanded its mining operation to Maniema, a province bordering South 

Kivu, which is less prone to conflict and the government is reinvesting tax 

income into the mining communities. According to USAID, a CFTI 

stakeholder, from October 2012 to December 2013, the initiative 

generated a total export value of more than $3 million.

Regional Certification Mechanism

In 2010, the International Conference on the Great Lakes Region 

(ICGLR) began working with an NGO to develop a regional certification 

mechanism to ensure that conflict minerals are fully traceable. ICGLR’s 

Regional Certification Mechanism (RCM) enables member countries and 

their mining companies to demonstrate where and under what conditions 

minerals were produced, allowing member governments to issue ICGLR 

regional certificates for those mineral shipments that are in compliance 

with the standards of the mechanism. The ICGLR issued its first 

certificate in November 2013 to a mine in Rwanda. According to an 

ICGLR official, the DRC launched its certificate program but had not yet 

issued any certificates as of November 2013. He added that Tanzania 

 48According to Solutions for Hope, its closed pipeline involved working through a defined 

set of key suppliers—mines (including artisanal cooperatives), smelter/processor, 

component manufacturer, and end user—identified in advance of initiating the project.
Page 28 GAO-14-575 Conflict Minerals

and Burundi may be able to issue certificates by the end of 2014. The 

ICGLR official noted several challenges in instituting the RCM in the DRC 

and the region. For example, he cited that it is logistically difficult to 

catalogue all mines in each country. In addition, the official noted that

training local officials to use the RCM software is difficult and time 

consuming. The official added that it takes member countries 1 year to 

prepare for all components associated with launching the RCM.

In the past year, one existing stakeholder has launched a new in-region 

responsible sourcing initiative and a new stakeholder has established an 

initiative.

Analytical Fingerprint Project

The German government’s Federal Institute for Geosciences and Natural 

Resources (BGR), an existing stakeholder, launched a new initiative in 

the past year. According to a representative, BGR’s primary role is to 

support the region’s governments and to build government capacity. 

Since 2013, BGR has initiated the Analytical Fingerprint Project to allow 

for independent verification of the origin of the conflict mineral by 

comparing the composition of tantalum, tin, and tungsten concentrate 

samples of a known origin with unknown samples, similar to a DNA test. 

According to a BGR official, the project has three types of units—sample 

preparation labs, high tech labs, and a management unit. To date, BGR 

has established sample preparation labs, located in Rwanda since 2013 

and in the DRC since 2014, where mineral ore samples are prepared for 

analysis. A third sample preparation lab is under construction in Burundi. 

BGR is in negotiations to establish a high tech lab in Tanzania, which 

receives and analyzes the samples from the preparation labs. 

Additionally, in 2013, according to a BGR official, BGR established a 

project management unit at the ICGLR headquarters in Burundi, which 

evaluates the raw data and produces the analytical fingerprints.

Better Sourcing Program Responsible-Sourcing Pilot

The Better Sourcing Program (BSP), a private company that offers an 

independently audited due diligence assurance program to enable 

companies to source tantalum, tin, tungsten, and gold from the region, is 

a new stakeholder in the region in 2013. The Better Sourcing Program 

established a pilot program that covers a tantalum supply chain 

originating from the Republic of the Congo (also known as CongoBrazzaville), which is the first responsible-sourcing initiative in that 

country. Better Sourcing Program officials stated that they chose to pilot 

New Initiatives Have Launched 

in the Region Since 2013
Page 29 GAO-14-575 Conflict Minerals

the initiative in the Republic of the Congo because no other scheme to 

support producers existed there, because the country is relatively conflict 

free, and because the government has been cooperative.

Some stakeholders that we interviewed noted various challenges to 

expanding or launching responsible-sourcing efforts in the DRC and 

adjoining countries. For example:

• Lack of infrastructure. Some stakeholders reported that inadequate 

infrastructure in the DRC and adjoining countries affects their ability to 

operate in the region and expand initiatives to new areas. 

Representatives from Solutions for Hope stated that infrastructure in 

the DRC cannot support a large-scale smelter. According to these 

representatives, the power supply in the DRC can be inconsistent 

and, because smelting facilities require a large, consistent power 

supply to function properly, all tin, tantalum, and tungsten currently 

are exported from the DRC and Rwanda for smelting.49

• Lack of government support. Some stakeholders reported some 

operational challenges related to the region’s national and provincial 

governments. For example, stakeholders involved in the Conflict Free 

Tin Initiative stated that sales of tin from their mine in South Kivu were 

halted for nearly 2 months in 2013 after the provincial government of 

the region imposed harsh taxes on the minerals mined there. 

Additionally, Solutions for Hope officials reported that the DRC’s 

current tax structure is not conducive to legitimizing gold and that 

expanding the initiative to include gold is therefore difficult.

• Lack of buyers for conflict minerals from conflict zones. Several 

stakeholders and agency officials reported that some companies are 

reluctant to buy minerals produced in the DRC and adjoining countries 

because of the high cost of the due diligence required by the DoddFrank Act and the perceived reputational risk. For example, according 

to one industry official, a major challenge to responsible sourcing in 

the region is that the cost of complying with the SEC rule makes it 

difficult for SEC-reporting companies to compete in the global market 

against companies that are not required to perform costly due 

diligence. In addition, an official from the Responsible Jewellery 

Council noted that gold is mined in many locations around the world 

 49According to Solutions for Hope officials, a tin smelter in the Katanga province is 

currently idle due to lack of consistent power, and another smelter in Rwanda, which is 

working toward certification by the Conflict-Free Smelter Program, has been idle for over 5 

years.

Stakeholders Face Operational 

Challenges in Expanding or 

Launching In-Region Initiatives
Page 30 GAO-14-575 Conflict Minerals

and that production costs must always be taken into account. She 

stated that because the cost of due diligence for gold is usually 

proportional to risk, mining and sourcing responsibly in the Great 

Lakes Region could become more expensive than in other, lower-risk 

areas and that this represents a challenge to responsible sourcing 

efforts in the region.

Some stakeholders and governments in the region provide publicly 

available information related to in-region mining of conflict minerals and 

responsible sourcing initiatives. According to industry officials, the amount 

of publicly available data reported by responsible sourcing initiatives has 

increased over the past year. We found that iTSCi publishes various 

reports on its public website as part of its due diligence system for its 

members. These reports provide production and export data for tin, 

tantalum, and tungsten, including amounts traced through the iTSCi 

program, from three provinces in the DRC and Rwanda, as well as the 

mineral sales in U.S. dollars (for more details, including the applicable 

quantitative data, see app. IV). Also on its website, iTSCi publishes thirdparty audits of member companies, which assess the extent to which the 

companies have implemented the OECD Due Diligence Guidance and 

evaluate the companies’ adherence to iTSCi’s traceability and due 

diligence procedure. Additionally, iTSCi publishes governance 

assessments covering a range of topics. Examples include the security 

and political situation in areas without an iTSCi presence and the risks 

and performance, relative to the OECD Due Diligence Guidance and the 

SEC rule, of stakeholders that are part of, or play a role in monitoring, the 

conflict minerals supply chain.50

A comparison of production data from the conflict-free sourcing initiatives 

in the context of each country’s or the region’s total production or exports 

of tin, tantalum, tungsten, or gold is not feasible, because no reliable, 

comprehensive data on the production or export of conflict minerals for 

the countries or region are available. However, some quantitative 

government data on the production and exports of conflict minerals from 

the DRC and adjoining countries are available (see app. V). For example, 

the DRC government has published data on production and exports of all 

four conflict minerals and the Rwandan government has published export 

 50According to an iTSCi official, the governance assessments also include summaries of 

all incidents that have occurred and how they have been mitigated or otherwise resolved.

Some Information about 

the Conflict Minerals Trade 

Is Publicly Available
Page 31 GAO-14-575 Conflict Minerals

and value data for tin, tantalum, and tungsten. In addition, the 

International Trade Centre, a joint agency of the World Trade 

Organization and the UN, collects export data from governments that 

provide some context for the amount of conflict minerals declared as 

exported from the region, although these data do not identify minerals 

from conflict-free mines (see app. VI).

Some stakeholders indicated that the ICGLR may, at some point, be able 

to provide production and export data of conflict minerals from its member 

states, mostly Dodd-Frank-affected countries. This information could 

increase transparency at the individual country level. ICGLR requires its 

member states to implement a chain-of-custody tracking system for 

conflict minerals and to transmit data on mineral flows (i.e., quantities and 

destinations) at regular intervals to be incorporated in the ICGLR 

Regional Mineral Tracking Database. According to an ICGLR official, this 

database is populated with three types of information: (1) a historical 

record of mine sites in each country, (2) types and quantities of minerals 

produced at each mine site, and (3) mineral flows from the mine sites. 

According to ICGLR documentation, the data are used to track, analyze, 

and reconcile regional mineral flows and will become publicly available to 

ensure ICGLR’s credibility. In November 2013, the ICGLR official stated 

that four of the 12 member countries had submitted information for the 

regional database: Rwanda, Uganda, the DRC, and, to a lesser extent, 

Burundi.

Since we reported in July 2013, no new population-based surveys related 

to sexual violence in the DRC, Uganda, Rwanda, or Burundi have been 

published. However, population-based surveys are underway, or being 

planned, in three of those countries—the DRC, Burundi, and Rwanda. In 

addition, some new case file data on sexual violence are available for all 

four countries. However, as we reported in 2011, case file data on sexual 

violence are not suitable for estimating a rate of sexual violence.

Little Additional 

Information on Rate 

of Sexual Violence in 

Eastern DRC and 

Adjoining Countries 

since July 2013
Page 32 GAO-14-575 Conflict Minerals

Although no new surveys related to sexual violence in the DRC, Uganda, 

Rwanda, or Burundi have been published since July 2013, populationbased surveys in the DRC, Burundi, and Rwanda are underway or 

planned by ICF International.51

Figure 4 shows the anticipated timelines for the population-based surveys 

on sexual violence that are currently underway or planned in the DRC, 

Burundi, and Rwanda. It also shows the publication dates for eight 

population-based surveys that provided data on the rate of sexual 

violence in eastern DRC, Rwanda, and Uganda that have been published 

since we started reporting on sexual violence in the region in 2011.

According to ICF International, data 

collection for a Demographic and Health Survey (DHS), which is a type of 

population-based survey, for the DRC is complete, but data resulting from 

the survey are not expected until September 2014 or later. ICF 

International also said that fieldwork for a DHS in Rwanda is likely to start 

in September or October 2014. ICF International indicated that a DHS is 

planned to start in Burundi in 2014; however, data collection may be 

delayed by funding gaps and, as a result, the survey may not take place 

until 2015.

 51ICF International implements the Demographic and Health Surveys (DHS) Program, 

which has provided technical assistance to more than 300 surveys in over 90 countries. 

The DHS Program provides capacity building to host-country implementing agencies 

through all survey stages, including survey design and sampling, training, field work, data 

tabulation and analysis, report writing, and dissemination and use of findings.

Several Population-Based 

Surveys Are Underway or 

Planned
Page 33 GAO-14-575 Conflict Minerals

Figure 4: Timeline of Population-Based Surveys Estimating the Rate of Sexual Violence in Eastern DRC, Rwanda, Uganda, 

and Burundi

Since 2013, some U.S. and UN agencies as well as researchers and an 

NGO have provided additional case file data on instances of sexual 

violence in the DRC and adjoining countries. In February 2014, State 

submitted its annual country reports on human rights practices to 

Congress, which provided the following data pertaining to sexual violence 

in the DRC, Burundi, and Uganda.52

• In the DRC, the government reported 18,729 cases of sexual violence 

in 2012.

For example,

• In Burundi, 3,781 cases of gender-based violence were reported in 

2010, according to a report compiled from family development centers 

throughout the country.

• In Uganda, 530 cases of rape were registered in 2012, and 301 of the 

alleged rapists were tried and convicted.

 52U.S. Department of State, Bureau of Democracy, Human Rights and Labor, Country 

Reports on Human Rights Practices for 2013, accessed May 18, 2014, 

http://www.state.gov/j/drl/rls/hrrpt/humanrightsreport/index.htm#wrapper.

Some Additional Case File 

Data on Sexual Violence 

Have Become Available 

since GAO’s 2013 Report
Page 34 GAO-14-575 Conflict Minerals

In addition, some UN entities reported case file information. For example:

• MONUSCO reported that between October 1, 2013, and December 5, 

2013, it recorded acts of sexual violence against at least 79 women 

and 28 girls in conflict-affected provinces in the DRC.53

• MONUSCO reported in March 2014 that sexual violence crimes 

continued to be committed by armed groups and that such crimes 

were allegedly committed against at least four women, 35 girls, and 

one man by elements of illegal armed forces and members of the 

Congolese military and police in January 2014.

• The United Nations Joint Human Rights Office reported in April 2014 

that between the period of January 2010 and December 2013, it 

registered 3,635 victims of sexual violence throughout the DRC.54

Moreover, the DRC government reported case file information. For 

example:

The 

report indicated that, for the reporting period, while more than half of 

the total alleged acts of sexual violence were committee by illegal 

armed groups, members of the Congolese national military committed 

less than half of the other alleged acts.

• A report published in June 2013 by the DRC Ministry of Gender, the 

Family, and Child, with support by the UN Population Fund, 

highlighted cases of sexual violence in seven provinces in the country: 

Bandundu, Bas Congo, Katanga, Kinshasa, North Kivu, Orientale, and 

South Kivu.55

 53UN Security Council, Report of the Secretary-General on the United Nations 

Organization Stabilization Mission in the Democratic Republic of the Congo, S/2013/757 

(New York, NY: Dec 17, 2013).

Data in the report indicate that 10,322 incidents of 

sexual and gender-based violence were reported for the seven 

provinces in 2011 and that the number increased to 15,654 incidents 

in 2012. While the data also indicate that most of these assaults were 

committed by people dressed in civilian clothes—85 percent in 2011 

and 78 percent in 2012—incidents involving armed groups between 

2011 and 2012 increased in South Kivu from 36 to 76 percent, 

respectively, and in North Kivu from 32 to 61 percent, respectively.

54Progress and Obstacles in the Fight Against Impunity for Sexual Violence in the 

Democratic Republic of the Congo, United Nations Joint Human Rights Office, April 2014.

55Extent of Sexual Violence in the DRC and Actions to Fight against the Phenomenon of 

2011 to 2012, DRC Ministry of Gender, the Family, and Child; Kinshasa, June 2013. This 

report was not publicly available before we issued our report in July 2013.
Page 35 GAO-14-575 Conflict Minerals

An NGO also published case file information. For example:

• Médecins sans Frontières reported in March 2014 that in 2012 it 

provided medical care to a total of 4,037 women, men, and children 

after incidents of sexual violence in different project locations in the 

DRC.56

Several factors make case file data unsuitable for estimating rates of 

sexual violence. First, because case file data are not aggregated across 

various sources, and because the extent to which various reports overlap 

is unclear, it is difficult to obtain complete data, or a sense of magnitude, 

from case files. Second, in case file data as well as surveys, time frames, 

locales, and definitions of sexual violence may be inconsistent across 

data collection operations. Third, case file data are not based on a 

random sample and the results of analyzing these data are not 

generalizable.

It reported treating, in a 5-week period in late 2012 through 

early 2013, 95 of those individuals in one camp for Internally 

Displaced People in North Kivu.

The long-running humanitarian crisis in eastern DRC, one of the most 

volatile areas in Africa, continues to be a concern for the U.S. government 

and the international community. As we have previously reported, section 

1502 of the Dodd-Frank Wall Street Reform and Consumer Protection 

Act, enacted in 2010, is part of the U.S. effort to address the perpetration 

of sexual violence and mass killings in the DRC by armed groups who 

profit from the exploitation and trading of conflict minerals. We have 

compiled stakeholder data on the production and trade of conflict 

minerals that demonstrates, to some extent, the degree of transparency 

related to the conflict minerals trade. The actions undertaken by U.S. 

agencies in response to the Act could facilitate SEC-reporting companies’

compliance with the SEC rule, promulgated pursuant to the Act, as they 

conduct due diligence and prepare the required annual reports disclosing 

the use and the origin of conflict minerals in their products. However, 

because Commerce has not met the Act’s requirement that it compile by 

January 2013 a list of smelters and refiners—considered the “choke 

point” of the conflict minerals supply chain—these companies lack a 

source of critical information about the conflict minerals supply chain. 

 56Medecins sans Frontieres, Everyday Emergency: Silent Suffering in the Democratic 

Republic of Congo, Amsterdam, 2014.

Conclusions
Page 36 GAO-14-575 Conflict Minerals

Some stakeholders indicated that a comprehensive list of conflict 

minerals smelters and refiners could enable companies that are subject to 

the SEC rule to maintain transparency of the supply chain, and also 

provide companies the information they need for their SEC-required 

conflict minerals disclosure reports. Commerce cited several challenges 

that have hindered its providing the required list to Congress. However, 

having an action plan with associated timeframes could better position 

Commerce to report on the status of its efforts to produce a final list and 

provide it to Congress and to hold its personnel accountable for 

completing related activities.

To give Congress a sense of Commerce’s efforts to produce a listing of 

all known conflict minerals processing facilities worldwide, as required by 

section 1502 of the Dodd-Frank Wall Street Reform and Consumer 

Protection Act, we recommend that the Secretary of Commerce provide 

to Congress a plan that outlines the steps, with associated timeframes, to 

develop and report the required information about smelters and refiners of 

conflict minerals worldwide.

We provided a draft of this report to SEC, State, USAID, and Commerce 

for their review. Commerce provided written comments, which we have 

reproduced in appendix VII. SEC and State provided technical comments, 

which we incorporated as appropriate. We also provided relevant portions 

of the draft report to some industry associations and other stakeholders of 

conflict minerals initiatives from whom we had obtained information during 

our review; some of these stakeholders provided technical comments that 

we incorporated as appropriate. 

In its written comments, Commerce noted in response to our 

recommendation that it had provided and briefed us on a detailed 

outreach action plan that set forth how it intended to assemble the list of 

conflict minerals processing facilities required by the Act. However, as we 

have noted in this report, the document that Commerce provided was an 

outreach plan, consisting of a list of stakeholders that Commerce 

intended to contact to obtain information on conflict minerals smelters and 

refiners. The plan did not indicate a timeframe for completing and 

submitting to Congress the required listing of conflict minerals processing 

facilities worldwide. Commerce concurred with our recommendation and 

noted that it will submit a listing of all known conflict minerals processing 

facilities worldwide to Congress by September 1, 2014. 

Recommendation for 

Executive Action

Agency and Third 

Party Comments and 

Our Evaluation
Page 37 GAO-14-575 Conflict Minerals

We are sending copies of this report to appropriate congressional 

committees. The report is also available at no charge on the GAO website 

at http://www.gao.gov/.

If you or your staffs have any questions about this report, please contact 

me at (202) 512-8612 or gianopoulosk@gao.gov. Contact points for our 

Offices of Congressional relations and Public Affairs may be found on the 

last page of this report. GAO staff who made key contributions to this 

report are listed in appendix VIII.

Kimberly M. Gianopoulos

Acting Director, International Affairs and Trade
Page 38 GAO-14-575 Conflict Minerals

List of Addressees

The Honorable Barbara Mikulski

Chairwoman

The Honorable Richard Shelby

Vice Chairman

Committee on Appropriations

United States Senate 

The Honorable Tim Johnson 

Chairman

The Honorable Mike Crapo

Ranking Member

Committee on Banking, Housing, and Urban Affairs

United States Senate

The Honorable Ron Wyden 

Chairman

The Honorable Orrin G. Hatch

Ranking Member

Committee on Finance

United States Senate 

The Honorable Robert Menendez

Chairman

The Honorable Bob Corker

Ranking Member

Committee on Foreign Relations 

United States Senate

The Honorable Hal Rogers

Chairman 

The Honorable Nita Lowey

Ranking Member

Committee on Appropriations

House of Representatives 

The Honorable Jeb Hensarling

Chairman

The Honorable Maxine Waters

Ranking Member

Committee on Financial Services

House of Representatives
Page 39 GAO-14-575 Conflict Minerals

The Honorable Ed Royce

Chairman

The Honorable Eliot Engel

Ranking Member

Committee on Foreign Affairs

House of Representatives 

The Honorable Dave Camp

Chairman

The Honorable Sander Levin

Ranking Member

Committee on Ways and Means

House of Representatives 
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-14-575 Conflict Minerals

To determine the extent, if any, to which relevant U.S. agencies have 

engaged in activities related to responsible sourcing of conflict minerals, 

we interviewed officials who are cognizant of conflict minerals issues from 

the Departments of Commerce and State (State) and the United States 

Agency for International Development (USAID), and the Securities and 

Exchange Commission (SEC). We reviewed Section 1502 of the DoddFrank Wall Street Reform and Consumer Protection Act (Pub. L. No. 111-

203) to identify the requirements for Commerce, State, SEC, and USAID 

related to implementation of section 1502. We also reviewed and 

analyzed reports and other documents from the agencies, such as the 

U.S. Strategy to Address the Linkages Between Human Rights Abuses, 

Armed Groups, Mining of Conflict Minerals, and Commercial Products; 

the conflict minerals rule; and maps of mineral-rich zones and areas 

under control of armed groups in the DRC. In addition, we reviewed and 

analyzed press releases, statements, plans, and guidance pertaining to 

conflict minerals and responsible sourcing that were issued by U.S. 

agencies. We also reviewed notes and agendas of responsible sourcing 

forums and other meetings attended by U.S. officials.

To analyze what is known about the status of, and any information 

provided by, initiatives focused on responsible sourcing of conflict 

minerals from the DRC and adjoining countries, we interviewed officials 

and reviewed and analyzed documents from State, USAID, and the 

United Nations Group of Experts on the Democratic Republic of the 

Congo (UNGoE); interviewed representatives and reviewed and analyzed 

guidance documents, reports, and presentations from foreign 

government, industry associations, multilateral organizations, companies, 

and nongovernmental organizations (NGOs). We selected these 

stakeholders based on their expertise on responsible sourcing issues, 

because they represented a range of perspectives on conflict minerals, 

and because we had established contacts with these entities on our last 

review.

1

 1

GAO, SEC Conflict Minerals Rule: Information on Responsible Sourcing and Companies 

Affected, 

In addition, some of the stakeholders we talked to have been 

working on the ground in the DRC. The stakeholders we spoke with 

constitute a nongeneralizable sample, and the information we gathered 

from them cannot be used to infer views of other stakeholders cognizant 

of conflict minerals issues. To determine which initiatives had expanded 

and which were new initiatives in the region, we interviewed U.S. agency 

GAO-13-689 (Washington, D.C.: July 18, 2013).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-14-575 Conflict Minerals

officials and relevant stakeholders and reviewed documentation from 

initiatives in the region. This report covers initiatives on which we have 

previously reported and new initiatives since our 2013 report, as 

described by stakeholders we interviewed.2

To demonstrate other sources of publicly available data on conflict 

minerals, we collected and analyzed stakeholder and government data 

covering 2003 through 2014. Because the data were not used to support 

findings, conclusions, or recommendations, we did not assess their 

reliability. To demonstrate the output of one of the in-region initiatives, we 

collected production and export data for the ITRI Supply Chain Initiative 

(iTSCi). We reviewed the production reports for three provinces in the 

DRC and for Rwanda published on iTSCi’s website, abbreviated the data 

to include those most relevant to this study, and converted the data to 

tons and thousands of U.S. dollars. A limitation of the data is that the 

disaggregated production data–by mineral and mine–are proprietary to 

iSTCi members, so it is not possible to quantify the total amount of any of 

the minerals separately. We also collected conflict mineral production and 

export data from the websites of the governments of the DRC and 

Rwanda and from the International Trade Centre. We are presenting 

these data in the appendixes of the report because these are the only 

publicly available data we found for sourcing conflict minerals from the 

region. There is no distinction in these data between minerals that are 

However, it is possible that 

the agency officials and stakeholders with whom we spoke may be 

unaware of other stakeholders and/or responsible sourcing initiatives 

active in the DRC and region. To determine the starting dates of the 

initiatives, we interviewed stakeholders and reviewed the websites of the 

various initiatives. To demonstrate what information stakeholders have 

reported regarding responsible sourcing initiatives, we reviewed and 

analyzed information published on the websites associated with the 

various responsible sourcing initiatives. When reporting on information 

provided by the initiatives and stakeholders, we are referring to 

information such as reports published, amount of minerals mined per 

region/country, amount of minerals exported, and value of minerals 

produced and exported, including data covering 2012 through 2014. The 

information gathered cannot be generalized and cannot be used to infer 

views of other stakeholders cognizant of conflict minerals issues.

 2

GAO, Conflict Minerals Disclosure Rule: SEC’s Actions and Stakeholder-Developed 

Initiatives, GAO-12-763 (Washington, D.C.: July 16, 2012) and GAO-13-689. 
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-14-575 Conflict Minerals

conflict-free and those that have supported armed groups. Moreover, 

none of these data can be generalized or be used to infer the total 

production or export of conflict minerals from the DRC and the adjoining 

countries.

In response to a mandate in the Dodd-Frank Wall Street Reform and 

Consumer Protection Act that GAO submit an annual report that 

assesses the rate of sexual violence in war-torn areas of the DRC and 

adjoining countries, we identified and assessed any additional published

information available on sexual violence in war-torn eastern DRC, as well 

as three adjoining countries that border the DRC—Rwanda, Uganda, and 

Burundi—since our 2013 report on sexual violence in these areas.3

During the course of our review, we interviewed officials from State and 

USAID and interviewed NGO representatives and researchers to discuss 

the collection of sexual violence-related data—including population-based 

surveys and case file data—in the DRC and adjoining countries. 

Specifically, we followed up with researchers and representatives from 

those groups we interviewed for our prior review on sexual violence rates 

in eastern DRC and adjoining countries, including a representative from 

the Human Rights Center at the University of California, Berkeley, School 

of Law and others officials. The team also traveled to New York City to 

meet with officials from the United Nations Population Fund, United 

Nations High Commissioner for Refugees, and the United Nations Special 

Representative of the Secretary-General on Sexual Violence in Conflict. 

We also conducted Internet literature searches to identify new academic 

articles containing any additional information on sexual violence since our 

2013 report.4

We conducted this performance audit from September 2013 to June 2014 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 3

GAO-13-689. We did not include in our current report information from preliminary 

studies or reports.

4

GAO-13-689.
Appendix II: State Department Map of Armed 

Groups Present at Mine Sites in the 

Democratic Republic of the Congo

Page 43 GAO-14-575 Conflict Minerals

Figure 5 depicts the most recent map published by the Department of 

State. The map focuses on the exploitation of tin, tantalum, tungsten, and 

gold in the provinces of North and South Kivu and parts of Orientale, 

Maniema, and Katanga provinces.

Appendix II: State Department Map of Armed 

Groups Present at Mine Sites in the 

Democratic Republic of the Congo
Appendix II: State Department Map of Armed 

Groups Present at Mine Sites in the 

Democratic Republic of the Congo

Page 44 GAO-14-575 Conflict Minerals

Figure 5: State Department Map of the Presence of Armed Groups at Mine Sites in the Democratic Republic of the Congo, as 

of February 2014
Appendix III: SEC Flowchart Summary of the 

Disclosure Process for the Final Conflict 

Minerals Rule

Page 45 GAO-14-575 Conflict Minerals

When the SEC adopted the conflict minerals rule in August 2012, it 

published a flowchart summary of the final rule to guide SEC-reporting 

companies affected by the rule through the disclosure process (see fig 6).

In general, the process reflects that an SEC-reporting company needs to 

(1) determine whether its manufactured products contain conflict 

minerals, (2) determine whether conflict minerals are necessary to the 

functionality or production of the product and if it originated in the DRC or 

an adjoining country, and (3) possibly conduct due diligence and 

potentially provide a Conflict Minerals Report.

Appendix III: SEC Flowchart Summary of the 

Disclosure Process for the Final Conflict 

Minerals Rule
Appendix III: SEC Flowchart Summary of the 

Disclosure Process for the Final Conflict 

Minerals Rule

Page 46 GAO-14-575 Conflict Minerals

Figure 6: SEC Flowchart Summary of Conflict Minerals Rule
Appendix III: SEC Flowchart Summary of the 

Disclosure Process for the Final Conflict 

Minerals Rule

Page 47 GAO-14-575 Conflict Minerals

Note: SEC indicated that the flowchart is intended to be used as a guide and that issuers should refer 

to the text in the rule for a more comprehensive description of the rule’s requirements. Further, SEC 

indicated that, as a result of the appeals court decision, SEC’s stay order, and SEC staff’s guidance, 

some of the steps outlined in the flowchart have been modified pending further action by SEC or a 

court.
Appendix IV: Sample Data from the ITRI Supply 

Chain Initiative

Page 48 GAO-14-575 Conflict Minerals

The ITRI Supply Chain Initiative (iTSCi) publishes qualitative and 

quantitative information on its projects in the DRC and Rwanda on its 

website. The information includes production data for minerals that have 

been mined and traded employing the iTSCi traceability system, audits of 

iTSCi member companies, and assessments of the political and security 

situation in various sites in the DRC and Rwanda. The mineral production 

and export data include minerals mined under the auspices of other 

stakeholder-led initiatives in the region. Almost all of the initiatives employ 

the iTSCi traceability system to track the mining and trading of minerals 

along the supply chain.1

One limitation of the data is that the production data–disaggregated by 

mineral and mine–are proprietary to iSTCi members. Therefore, it is not 

possible to quantify the total quantity or value of any of the minerals 

separately.2

Tables 2-7 provide iTSCi production in metric tons and mineral sales in 

thousands of U.S. dollars for tin, tungsten, and tantalum coming from 

several provinces in the DRC, including Maniema, South Kivu, and 

Katanga.

Table 2: Production of Minerals from Maniema Covered by iTSCi for Q1 and Q2 of 

2013, in Metric Tons

2013 Tin Tin/Tantaluma Tin/Tungstena Tantalum/Tungstena Tungsten

Q1 17 11 1

Q2 225 1 17 1

Total 242 1 28 1 1

Source: GAO based on iTSCi data. | GAO-14-575

Note: Empty cells indicate no recorded production.

a

iTSCi data include traced material that are reported as combinations of more than one mineral. 

 1

Because the data were not used to support findings, conclusions, or recommendations, 

we did not assess their reliability.

2

Detailed data showing production and exports of each of the conflict minerals are 

proprietary to iTSCi members.

Appendix IV: Sample Data from the ITRI 

Supply Chain Initiative
Appendix IV: Sample Data from the ITRI Supply 

Chain Initiative

Page 49 GAO-14-575 Conflict Minerals

Table 3: Sales of Minerals from Maniema Covered by iTSCi for Q1 and Q2 of 2013, in 

Thousands of U.S. Dollars

2013 Tin Tin/Tantaluma Tin/Tungstena Tantalum/Tungstena Tungsten

Q1 $87 $46 $1

Q2 $1,163 $5 $84 $3

Total $1,250 $5 $130 $3 $1

Source: GAO based on iTSCi data. | GAO-14-575

Note: Empty cells indicate no recorded sales.

a

iTSCi data include traced material that are reported as combinations of more than one mineral.

Table 4: Production of Minerals from South Kivu Covered by iTSCi for Q4 of 2012 

through Q2 of 2013, in Metric Tons

Year/Quarter Tin Tin/Tantaluma

2012/Q4 181

2013/Q1 200

2013/Q2 80 1

Total 460 1

Source: GAO based on iTSCi data. | GAO-14-575

Note: Empty cells indicate no recorded production. Totals may not add due to rounding. 

a

iTSCi data include traced material that are reported as combinations of more than one mineral.

Table 5: Sales of Minerals from South Kivu Covered by iTSCi for Q4 of 2012 through 

Q2 of 2013, in Thousands of U.S. Dollars

Year/Quarter Tin Tin/Tantaluma

2012/Q4 $760

2013/Q1 $800

2013/Q2 $286 $3

Total $1,847 $3

Source: GAO based on iTSCi data. | GAO-14-575

Note: Empty cells indicate no recorded sales. Totals may not add due to rounding. 

a

iTSCi data include traced material that are reported as combinations of more than one mineral.
Appendix IV: Sample Data from the ITRI Supply 

Chain Initiative

Page 50 GAO-14-575 Conflict Minerals

Table 6: Production of Minerals from Katanga Covered by iTSCi for Q2 of 2011 through Q2 of 2013, in Metric Tons

Year/Quarter Tin Tin/Tantaluma Tin/Tungstena Tantalum Tantalum/Tungstena Tungsten

2011/Q2 796 193 2 54 3

2011/Q3 1,436 234 2 51 16

2011/Q4 779 121 2 128 26

2012/Q1 753 252 15 114 12

2012/Q2 651 275 40 60 2 15

2012/Q3 671 258 18 64 2 40

2012/Q4 497 188 7 45 29

2013/Q1 340 211 7 34 9

2013/Q2 648 441 2 40 0.4 6

Total 6,572 2,172 97 588 3 155

Source: GAO based on iTSCi data. | GAO-14-575

Note: Empty cells indicate no recorded production. Totals may not add due to rounding. 

a

iTSCi data include traced material that are reported as combinations of more than one mineral.

Table 7: Sales of Minerals from Katanga Covered by iTSCi for Q2 of 2011 through Q2 of 2013, in Thousands of U.S. Dollars

Year/Quarter Tin Tin/Tantaluma Tin/Tungstena Tantalum Tantalum/Tungstena Tungsten

2011/Q2 $5,166 $1,290 $14 $1,548 $21

2011/Q3 $9,839 $1,746 $18 $1,733 $122

2011/Q4 $4,072 $718 $40 $4,448 $152

2012/Q1 $4,224 $1,783 $67 $3,758 $70

2012/Q2 $3,701 $1,811 $193 $2,012 $7 $97

2012/Q3 $3,352 $1,720 $172 $2,114 $5 $181

2012/Q4 $2,906 $1,268 $106 $1,571 $105

2013/Q1 $2,112 $1,449 $38 $1,092 $74

2013/Q2 $3,744 $3,583 $11 $1,502 $2 $19

Total $39,117 $15,367 $659 $19,778 $15 $840

Source: GAO based on iTSCi data. | GAO-14-575

Note: Empty cells indicate no recorded sales. Totals may not add due to rounding. 

a

iTSCi data include traced material that are reported as combinations of more than one mineral.

Tables 8 and 9 provide iTSCi production in tons and mineral sales in 

thousands of U.S. dollars for tin, tungsten and tantalum in Rwanda.
Appendix IV: Sample Data from the ITRI Supply 

Chain Initiative

Page 51 GAO-14-575 Conflict Minerals

Table 8: Production of Minerals from Rwanda Covered by iTSCi for Q2 of 2011 through Q2 of 2013, in Metric Tons

Year/Quarter Tin Tin/Tantaluma Tin/Tungstena Tin/Tantalum/Tungstena Tantalum Tantalum/Tungstena Tungsten

2011/Q2 1,393 442 3 3 56 1 353

2011/Q3 1,318 406 1 4 56 438

2011/Q4 1,387 381 14 1 41 528

2012/Q1 825 316 8 3 102 3 575

2012/Q2 671 397 5 16 108 1 605

2012/Q3 780 509 4 26 162 1 582

2012/Q4 842 489 2 24 165 2 454

2013/Q1 915 678 1 3 178 538

2013/Q2 827 799 1 248 486

Total 8,958 4,417 39 79 1,115 8 4,560

Source: GAO based on iTSCi data. | GAO-14-575

Note: Empty cells indicate no recorded production. Totals may not add due to rounding.

a

iTSCi data include traced material that are reported as combinations of more than one mineral.

Table 9: Sales of Minerals from Rwanda Covered by iTSCi for Q2 of 2011 through Q2 of 2013, in Thousands of U.S. Dollars

Year/

Quarter Tin Tin/Tantaluma Tin/Tungstena Tin/Tantalum/Tungstena Tantalum

Tantalum/

Tungstena Tungsten

2011/Q2 $11,481 $6,217 $32 $25 $1,095 $8 $1,988

2011/Q3 $9,533 $4,778 $16 $26 $972 $2,935

2011/Q4 $9,333 $4,423 $154 $10 $720 $3,608

2012/Q1 $4,874 $4,383 $92 $26 $2,068 $17 $4,007

2012/Q2 $3,369 $4,980 $31 $98 $2,098 $15 $4,691

2012/Q3 $4,273 $6,394 $27 $176 $3,473 $12 $4,891

2012/Q4 $6,026 $8,008 $26 $263 $4,148 $35 $4,235

2013/Q1 $6,982 $11,031 $19 $59 $5,654 $6,678

2013/Q2 $5,988 $14,857 $24 $8,331 $4,605

Total $61,859 $65,070 $421 $683 $28,560 $87 $37,637

Source: GAO based on iTSCi data. | GAO-14-575

Note: Empty cells indicate no recorded sales. Totals may not add due to rounding.

a

iTSCi data include traced material that are reported as combinations of more than one mineral.
Appendix V: Conflict Mineral Production and 

Export Data as Reported by the DRC and 

Rwandan Governments

Page 52 GAO-14-575 Conflict Minerals

The DRC Ministry of Mines published data on the volume of production 

and exports for tin, tantalum, tungsten, and gold for 2003-2012 (see 

tables 10-13).1

Table 10: Total Volume of Tin Production and Export from DRC for 2003-2012, in 

Metric Tons

Production Export

2003 2,986 2,986

2004 2,317 2,945

2005 5,171 5,971

2006 5,528 2,388

2007 16,050 14,694

2008 20,013 19,189

2009 16,584 15,512

2010 11,943 13,415

2011 8,921 9,267

2012 7,189 8,018

Total 96,702 94,385

Source: GAO based on DRC Ministry of Mines. | GAO-14-575

 1

The DRC Ministry of Mines statistics also include production and export data for other 

minerals. Because the data were not used to support findings, conclusions, or 

recommendations, we did not assess their reliability.

Appendix V: Conflict Mineral Production and 

Export Data as Reported by the DRC and 

Rwandan Governments
Appendix V: Conflict Mineral Production and 

Export Data as Reported by the DRC and 

Rwandan Governments

Page 53 GAO-14-575 Conflict Minerals

Table 11: Total Volume of Tantalum Production and Export from DRC for 2003-2012, 

in Metric Tons

Production Export

2003 47 47

2004 78 32

2005 184 185

2006 31 24

2007 393 393

2008 530 531

2009 509 464

2010 492 440

2011 2,199 536

2012 574 586

Total 5,037 3,238

Source: GAO based on DRC Ministry of Mines. | GAO-14-575

Table 12: Total Volume of Tungsten Production and Export from DRC for 2003-2012, 

in Metric Tons

Production Export

2003 No data 100

2004 272 190

2005 405 311

2006 1,001 471

2007 1,265 1,194

2008 621 725

2009 458 365

2010 44 45

2011 84 87

2012 197 71

Total 4,347 3,559

Source: GAO based on DRC Ministry of Mines. | GAO-14-575
Appendix V: Conflict Mineral Production and 

Export Data as Reported by the DRC and 

Rwandan Governments

Page 54 GAO-14-575 Conflict Minerals

Table 13: Total Volume of Gold Production and Export from DRC for 2003-2012, in 

Metric Tons

Production Export

2003 No data No data

2004 0.7 0.0

2005 0.6 0.6

2006 0.3 0.1

2007 0.1 0.1

2008 0.1 0.1

2009 0.2 0.2

2010 0.2 0.2

2011 0.3 0.2

2012 2.8 2.4

Total 5.3 3.9

Source: GAO based on DRC Ministry of Mines. | GAO-14-575

The Rwanda Natural Resources Authority published data on the volume 

and value of tin, tantalum and tungsten exported from Rwanda from 

January to August of 2013 (see tables 14 and 15).2

Table 14: Total Volume of Tin, Tantalum, and Tungsten Exports from Rwanda 

January-August 2013, in Metric Tons

Tin Tantalum Tungsten

January 421 84 184

February 224 48 130

March 475 284 185

April 510 251 230

May 458 273 157

June 267 212 177

July 396 288 151

August 407 245 164

Total 3,158 1,686 1,378

Source: GAO based on Rwanda Natural Resources Authority. | GAO-14-575

Note: Totals may not add due to rounding. 

 2

Because the data were not used to support findings, conclusions, or recommendations, 

we did not assess their reliability.
Appendix V: Conflict Mineral Production and 

Export Data as Reported by the DRC and 

Rwandan Governments

Page 55 GAO-14-575 Conflict Minerals

Table 15: Total Value of Tin, Tantalum, and Tungsten Exports from Rwanda 

January-August 2013, in Thousands of U.S. Dollars

Tin Tantalum Tungsten

January $5,386 $4,953 $2,178

February $2,803 $3,012 $1,564

March $8,314 $16,379 $2,118

April $6,352 $15,736 $3,915

May $5,365 $16,583 $2,075

June $3,206 $12,373 $2,559

July $4,297 $17,822 $2,103

August $4,509 $15,144 $2,277

Total $40,233 $102,002 $18,789

Source: GAO based on Rwanda Natural Resources Authority. | GAO-14-575

Note: Totals may not add due to rounding.
Appendix VI: Conflict Minerals Data from the 

International Trade Centre Data on Global 

Conflict Mineral Imports

Page 56 GAO-14-575 Conflict Minerals

The International Trade Centre (ITC), a joint agency of the World Trade 

Organization and the United Nations (UN) compiles a Trade Map with 

data including the global exports in tons and export value of tin, tantalum, 

tungsten and gold from the DRC and adjoining countries, as available for 

fiscal years 2009-2013 (see tables 16-31 for ITC data as of June 2014).1

These data do not provide a comprehensive depiction of the flow of 

conflict minerals exported from the DRC and adjoining countries; rather, 

they are an estimate based on imports data from reporting partner 

countries. Furthermore, these data may include imports of conflict 

minerals that have financed armed groups.

The ITC calculated these data using the UN Commodity Trade Statistics 

Database, which compiles trade data from UN member countries.

2

In many instances, there are no data listed for a particular mineral or 

year. There were no data for import volume or value of conflict minerals in 

the ITC database for the Republic of the Congo (Congo-Brazzaville) or 

South Sudan.

Table 16: ITC Estimates of Exports of Conflict Minerals from the Democratic 

Republic of the Congo for Fiscal Years 2009-2013, in Metric Tons

Tin Tantalumb Tungsten Gold

FY2009 160a 121a 471a No quantitya

FY2010 2,589a 252a 87a 0 a

FY2011 510a 101a 10a 0 a

FY2012 1,670a 326a 0 a

FY2013 2,621a 329a 95a 0 a

Total 7,550 1,129 663 0a

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. “No quantity” means that the country under review has reported a value but no 

quantity for the product and partner under review. Empty cells indicate that no partner country has 

reported importation of that mineral from that country. 

 1

The Trade Map (or Market Access Map, Investment Map and Standards Map, 

respectively), International Trade Centre, www.intracen.org/marketanalysis. 

2

Because the data were not used to support findings, conclusions, or recommendations, 

we did not assess their reliability.

Appendix VI: Conflict Minerals Data from the 

International Trade Centre Data on Global 

Conflict Mineral Imports 
Appendix VI: Conflict Minerals Data from the 

International Trade Centre Data on Global 

Conflict Mineral Imports

Page 57 GAO-14-575 Conflict Minerals

a

According to the ITC, these estimates of exports have been reconstructed on the basis of data 

reported by importing partner countries, known as mirror statistics. The ITC states that mirror 

statistics are a “second-best solution” when no data exist but are subject to limitations, including the 

omission of non-reporting countries, particularly in Africa.

b

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.

Table 17: ITC Estimates of Export Value of Conflict Minerals from the DRC for F

Fiscal Years 2009-2013, in Thousands of U.S. Dollars

Tin Tantalumb Tungsten Gold

FY2009 $1,061a $2,575a $4,357a $1,251a

FY2010 $23,045a $5,161a $806a $1,140a

FY2011 $8,786a $9,131a $263a $4,426a

FY2012 $17,719a $24,006a $1,394a

FY2013 $32,628a $22,142a $1,339a $2,729a

Total $83,239 $63,015 $6,765 $10,940

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, empty cells indicate that no partner country has reported importation of 

that mineral from that country. 

a

According to the ITC, these estimates of exports have been reconstructed on the basis of data 

reported by importing partner countries, known as mirror statistics. The ITC states that mirror 

statistics are a “second-best solution” when no data exist, but are subject to limitations, including the 

omission of non-reporting countries, particularly in Africa.

b

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.

Table 18: ITC Estimates of Exports of Conflict Minerals from Angola for Fiscal Years

2009-2012, in Metric Tons

Tin Tantalumb Tungsten Gold

FY2009

FY2010

FY2011 No quantitya 0

FY2012 19a

FY2013 No quantitya 28a

Total 47 0

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. “No quantity” means that the country under review has reported a value but no 

quantity for the product and partner under review. Empty cells indicate that no partner country has 

reported importation of that mineral from that country. 

a

According to the ITC, these estimates of exports have been reconstructed on the basis of data 

reported by importing partner countries, known as mirror statistics. The ITC states that mirror 
Appendix VI: Conflict Minerals Data from the 

International Trade Centre Data on Global 

Conflict Mineral Imports

Page 58 GAO-14-575 Conflict Minerals

statistics are a “second-best solution” when no data exist ,but are subject to limitations, including the 

omission of non-reporting countries, particularly in Africa.

b

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.

Table 19: ITC Estimates of Export Value of Conflict Minerals from Angola for Fiscal 

Years 2009-2013, in Thousands of U.S. Dollars

Tin Tantalumb Tungsten Gold

FY2009

FY2010

FY2011 $0a $90a

FY2012 $31a

FY2013 $0a $7

Total $0 $38 $0 $90

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. Empty cells indicate that no partner country has reported importation of that 

mineral from that country. 

a

According to the ITC, these estimates of exports have been reconstructed on the basis of data 

reported by importing partner countries, known as mirror statistics. The ITC states that mirror 

statistics are a “second-best solution” when no data exist, but are subject to limitations, including the 

omission of non-reporting countries, particularly in Africa.

b

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.

Table 20: ITC Estimates of Exports of Conflict Minerals from Burundi for Fiscal 

Years 2009-2012, in Metric Tons

Tin Tantaluma Tungsten Gold

FY2009 26 0 264 1

FY2010 32 0 503 0

FY2011 0 17 330 1

FY2012 0 0 32 2

FY2013 No quantity 76 148 3

Total 58 93 1,277 7

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. “No quantity” means that the country under review has reported a value but no 

quantity for the product and partner under review. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.
Appendix VI: Conflict Minerals Data from the 

International Trade Centre Data on Global 

Conflict Mineral Imports

Page 59 GAO-14-575 Conflict Minerals

Table 21: ITC Estimates of Export Value of Conflict Minerals from Burundi for Fiscal 

Years 2009-2013, in Thousands of U.S. Dollars

Tin Tantaluma Tungsten Gold

FY2009 $175 $0 $1,547 $28,979

FY2010 $297 $0 $2,951 $13,003

FY2011 $15 $20 $4,607 $59,047

FY2012 $0 $0 $226 $105,196

FY2013 $0 $2,753 $1,776 $121,470

Total $487 $2,773 $11,107 $327,695

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.

Table 22: ITC Estimates of Exports of Conflict Minerals from Central African 

Republic for Fiscal Years 2009-2012, in Metric Tons

Tin Tantaluma Tungsten Gold

FY2009 24

FY2010 49

FY2011 21

FY2012 6

FY2013 691

Total 791

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, empty cells indicate that no partner country has reported importation of 

that mineral from that country. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.
Appendix VI: Conflict Minerals Data from the 

International Trade Centre Data on Global 

Conflict Mineral Imports

Page 60 GAO-14-575 Conflict Minerals

Table 23: ITC Estimates of Export Value of Conflict Minerals from Central African 

Republic for Fiscal Years 2009-2013, in Thousands of U.S. Dollars

Tin Tantaluma Tungsten Gold

FY2009 $473

FY2010 $1,277

FY2011 $2,509

FY2012 $1,367

FY2013 $318

Total $5,944

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, empty cells indicate that no partner country has reported importation of 

that mineral from that country. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.

Table 24: ITC Estimates of Exports of Conflict Minerals from Rwanda for Fiscal 

Years 2009-2012, in Metric Tons

Tin Tantaluma Tungsten Gold

FY2009 5,224 958 945 0

FY2010 6,477 827 879 0

FY2011 7,314 915 784 0

FY2012 4,658 1,139 1,372 0

FY2013 4,820 2,466 2,119 0

Total 28,493 6,305 6,099 0

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.
Appendix VI: Conflict Minerals Data from the 

International Trade Centre Data on Global 

Conflict Mineral Imports

Page 61 GAO-14-575 Conflict Minerals

Table 25: ITC Estimates of Export Value of Conflict Minerals from Rwanda for Fiscal 

Years 2009-2013, in Thousands of U.S. Dollars

Tin Tantaluma Tungsten Gold

FY2009 $34,235 $18,082 $6,283 $856

FY2010 $65,834 $20,034 $7,254 $170

FY2011 $101,921 $39,000 $11,677 0

FY2012 $52,912 $56,698 $21,354 0

FY2013 $57,957 $134,575 $28,866 0

Total $312,859 $268,389 $75,434 $1,026

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.

Table 26: ITC Estimates of Export of Conflict Minerals from Tanzania for Fiscal 

Years 2009-2012, in Metric Tons

Tin Tantaluma Tungsten Gold

FY2009 0 0 0 402

FY2010 1 0 0 325

FY2011 66 160 0 43

FY2012 71 112 0 319

FY2013 57 No quantity No quantity 140

Total 195 272 0 1,229

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. “No quantity” means that the country under review has reported a value but no 

quantity for the product and partner under review.

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.
Appendix VI: Conflict Minerals Data from the 

International Trade Centre Data on Global 

Conflict Mineral Imports

Page 62 GAO-14-575 Conflict Minerals

Table 27: ITC Estimates of Export Value of Conflict Minerals from Tanzania for 

Fiscal Years 2009-2013, in Thousands of U.S. Dollars

Tin Tantaluma Tungsten Gold

FY2009 $0 $0 $0 $818,598

FY2010 $5 $0 $0 $966,077

FY2011 $373 $59 $0 $1,718,196

FY2012 $351 $153 $0 $1,863,327

FY2013 $329 $0 $0 $1,549,580

Total $1,058 $212 $0 $6,915,778

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.

Table 28: ITC Estimates of Exports of Conflict Minerals from Uganda for Fiscal 

Years 2009-2012, in Metric Tons

Tin Tantaluma Tungsten Gold

FY2009 7 No quantity 0 1

FY2010 No quantity No quantity 0 1

FY2011 0 No quantity No quantity 0

FY2012 No quantity No Quantity 100 0

FY2013 12 8 91 0

Total 19 8 191 2

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. “No quantity” means that the country under review has reported a value but no 

quantity for the product and partner under review. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.
Appendix VI: Conflict Minerals Data from the 

International Trade Centre Data on Global

Conflict Mineral Imports

Page 63 GAO-14-575 Conflict Minerals

Table 29: ITC Estimates of Export Value of Conflict Minerals from Uganda for Fiscal 

Years 2009-2013, in Thousands of U.S. Dollars

Tin Tantaluma Tungsten Gold

FY2009 $2 $0 $0 $13,100

FY2010 $0 $0 $0 $30,072

FY2011 $1 $0 $0 $6,795

FY2012 $0 $0 $979 $9,163

FY2013 $128 $22 $972 $3,128

Total $131 $22 $1,951 $62,258

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.

Table 30: ITC Estimates of Exports of Conflict Minerals from Zambia for Fiscal 

Years 2009-2012, in Metric Tons

Tin Tantaluma Tungsten Gold

FY2009 27 No quantity 0 695

FY2010 0 No quantity 23 555

FY2011 28 0 72 2

FY2012 0 No quantity 0 1,492

FY2013 6 0 0 4

Total 61 0 95 2,748

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. “No quantity” means that the country under review has reported a value but no 

quantity for the product and partner under review. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.
Appendix VI: Conflict Minerals Data from the 

International Trade Centre Data on Global 

Conflict Mineral Imports

Page 64 GAO-14-575 Conflict Minerals

Table 31: ITC Estimates of Export Value of Conflict Minerals from Zambia for Fiscal 

Years 2009-2013, in Thousands of U.S. Dollars

Tin Tantaluma Tungsten Gold

FY2009 $77 $0 $0 $19,004

FY2010 $1 $0 $12 $46,411

FY2011 $50 $0 $6 $81,040

FY2012 $0 $0 $0 $140,744

FY2013 $4 $0 $0 $164,079

Total $132 $0 $18 $451,278

Source: GAO analysis of Trade Map data. | GAO-14-575

Note: According to the ITC, if there is no record in the export dataset for a specific mineral and a 

specific partner country, they consider that the country has not exported the mineral for that year and 

publish a zero value. 

a

Export data for tantalum ores and concentrates also include exports of niobium and vanadium ores 

and concentrates.
Appendix VII: Comments from the Department 

of Commerce

Page 65 GAO-14-575 Conflict Minerals

Appendix VII: Comments from the 

Department of Commerce
Appendix VII: Comments from the Department 

of Commerce

Page 66 GAO-14-575 Conflict Minerals
Appendix VIII: GAO Contacts and Staff 

Acknowledgments

Page 67 GAO-14-575 Conflict Minerals

Kimberly M. Gianopoulos, (202) 512-8612 or gianopoulosk@gao.gov

In addition to the individual named above, Godwin Agbara (Assistant 

Director), Russ Burnett, Etana Finkler, Justin Fisher, Julia Jebo Grant, 

Ernie Jackson, Jill Lacey, Reid Lowe, Andrea Riba Miller, and John 

O’Trakoun made key contributions to this report.

Appendix VIII: GAO Contacts and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(320998)
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