SEC CONFLICT 

MINERALS RULE

Initial Disclosures 

Indicate Most 

Companies Were 

Unable to Determine 

the Source of Their 

Conflict Minerals

Report to Congressional Committees

August 2015

GAO-15-561

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-561, a report to 

congressional committees

August 2015

SEC CONFLICT MINERALS RULE

Initial Disclosures Indicate Most Companies Were 

Unable to Determine the Source of Their Conflict 

Minerals

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 

the United Nations. Congress included 

a provision in the 2010 Dodd-Frank 

Wall Street Reform and Consumer 

Protection Act that, among other 

things, directed SEC to promulgate 

disclosure and reporting regulations 

regarding the use of conflict minerals 

from the DRC and adjoining countries. 

The act also directed State and USAID 

to develop a strategy to address the 

linkages among human rights abuses, 

armed groups, the mining of conflict 

minerals, and commercial products.

This report examines (1) company 

disclosures filed with SEC for the first 

time in 2014 in response to the SEC 

conflict minerals disclosure rule; and 

(2) State and USAID actions related to 

the U.S. conflict minerals strategy in 

the DRC region. This report also 

includes information on sexual violence 

in the DRC and three adjoining 

countries. GAO reviewed and analyzed

relevant documents and data and 

interviewed officials from relevant U.S. 

agencies and nongovernmental, 

industry, and international 

organizations; and analyzed a random 

sample of company disclosures from 

the SEC database that was sufficiently 

large to produce estimates for all 

companies that filed. GAO also 

traveled to the DRC, Rwanda, and 

Burundi to conduct field work.

What GAO Recommends

GAO is not making any

recommendations.

What GAO Found

According to a generalizable sample GAO reviewed, company disclosures filed 

with the Securities and Exchange Commission (SEC) for the first time in 2014 in 

response to the SEC conflict minerals disclosure rule indicated that most 

companies were unable to determine the source of their conflict minerals. 

Companies that filed disclosures used one or more of the four “conflict 

minerals”—tantalum, tin, tungsten, and gold—determined by the Secretary of 

State to be financing conflict in the Democratic Republic of the Congo (DRC) or 

adjoining countries. Most companies were based in the United States (87 

percent). Almost all of the companies (99 percent) reported performing countryof-origin inquiries for conflict minerals used. Companies GAO spoke to cited 

difficulty obtaining necessary information from suppliers because of delays and

other challenges in communication. Most of the companies (94 percent) reported 

exercising due diligence on the source and chain of custody of conflict minerals

used. However, most (67 percent) were unable to determine whether those

minerals came from the DRC or adjoining countries (Covered Countries), and

none could determine whether the minerals financed or benefited armed groups

in those countries. Companies that disclosed that conflict minerals in their 

products came from covered countries (4 percent) indicated that they are or will 

be taking action to address the risks associated with the use and source of 

conflict minerals in their supply chains. For example, one company indicated that 

it would notify suppliers that it intends to cease doing business with suppliers 

who continue to source conflict minerals from smelters that are not certified as 

conflict-free.

a

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

(USAID) officials reported taking actions to implement the U.S. conflict minerals 

strategy, but a difficult operating environment complicates this implementation. 

The agencies reported supporting a range of initiatives including validation of 

conflict-free mine sites and strengthening traceability mechanisms that minimize 

the risk that minerals that have been exploited by illegal armed groups will enter 

the supply chain. As a result, according to the agencies, 140 mine sites have 

been validated and competition within conflict-free traceability systems has 

benefited artisanal miners and exporters. Implementation of the U.S conflict 

minerals strategy faces multiple obstacles outside the control of the U.S.

government. For example, eastern DRC is plagued by insecurity because of the 

presence of illegal armed groups and some corrupt members of the national 

military, weak governance, and poor infrastructure.

Covered Countries: Angola, Burundi, Central African Republic, the Democratic Republic of the 

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

View GAO-15-561. For more information, 

contact Kimberly Gianopoulos at (202) 512-

8612 or GianopoulosK@gao.gov.
Letter 1

Background 3

First Company Filings in Response to the SEC Rule Are Fewer 

Than SEC Estimated and Provide Limited Insights Regarding 

Country of Origin and Chain of Custody 11

State and USAID Actions to Implement the U.S. Conflict Minerals 

Strategy Have Yielded Some Results, but Conditions Remain 

Difficult 23

Additional Information Available on Rate of Sexual Violence in 

Eastern DRC and Adjoining Countries since GAO’s June 2014 

Report 38

Agency Comments 46

Appendix I Objectives, Scope, and Methodology 49

Appendix II Description of Litigation and Resulting Guidance Related to the 

“DRC Conflict Undeterminable” Classification 52

Appendix III GAO Contacts and Staff Acknowledgments 53

Tables

Table 1: USAID-Reported Actions to Promote an Appropriate Role 

for Security Forces, as of April 2015 24

Table 2: USAID-Reported Actions to Enhance Civilian Regulation 

of the DRC Minerals Trade, as of April 2015 28

Table 3: Reported Actions to Protect Artisanal Miners and Local 

Communities, as of April 2015 31

Table 4: Reported Actions to Help Strengthen Regional and 

International Efforts, as of April 2015 33

Table 5: Reported Actions to Promote Due Diligence and 

Responsible Trade through Public Outreach, as of April 

201534

Table 6: 2007 and 2013-2014 DHS Data on the Rates of Sexual 

Violence Reported by Women in the DRC, Ages 18-49, by 

Percentage 41

Contents
Figures

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

Provinces and Adjoining Countries4

Figure 2: SEC Flowchart Summary of the Conflict Minerals 

Disclosure Rule 12

Figure 3: Percentage of Companies That Reported in Response to 

the SEC Conflict Minerals Disclosure Rule in 2014 That 

They Used Conflict Minerals in Calendar Year 2013 14

Figure 4: Simplified Conflict Minerals Supply Chain Showing Tiers 

of Suppliers 17

Figure 5: The Securities and Exchange Commission (SEC) 

Conflict Minerals Disclosure Rule Timeline 21

Figure 6: A Bag of Tantalum Ore at a DRC Mine Being Prepared 

for “Tagging,” a Method to Trace Origin, and Export 26

Figure 7: A Bag of Tin Ore at a Rwandan Mine Tagged for Export 27

Figure 8: Artisanal Miners at a Tantalum Mine in the Democratic 

Republic of the Congo 29

Figure 9: Artisanal Miners at a Gold Mine in Burundi 30

Figure 10: Stuck Vehicle during a Visit by GAO Team to a Mine 

Site in Eastern DRC (November, 2014) 37

Figure 11: Timeline of Population-Based Surveys Estimating the 

Rate of Sexual Violence in Eastern DRC, Rwanda, 

Uganda, and Burundi 43
Abbreviations

CFSI Conflict-Free Sourcing Initiative 

CMR Conflict Minerals Report

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 

EDGAR Electronic Data Gathering, Analysis, and 

Retrieval 

FDLR Forces Democratiques de Liberation du 

Ruwanda

GDRC DRC government

HAI Heartland Alliance International

ICGLR International Conference on the Great 

Lakes Region 

IOM International Organization for Migration

IPIS International Peace Information Service

IPSA Independent Private Sector Audit

MONUSCO UN Organization Stabilization Mission in the 

Democratic Republic of the Congo

MPSMRM Ministry of Planning and Implementation of 

the Modern Revolution 

MSP Ministry of Public Health

NGO nongovernmental organization 

OECD Organization for Economic Co-operation 

and Development 

PPA Public-Private Alliance for Responsible 

Minerals Trade 

RCOI reasonable country-of-origin inquiry 

SAM Save Act Mine

SD Specialized Disclosure

SEC Securities and Exchange Commission 

Securities Exchange Act Securities Exchange Act of 1934

State United States Department of State 

UN United Nations 

UNDP United Nations Development Program

UNFPA United Nations Population Fund 

UNGOE UN Group of Experts

USAID United States Agency for International 

Development
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Page 1 GAO-15-561 Congo Conflict Minerals

441 G St. N.W.

Washington, DC 20548

August 18, 2015

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. An 

estimate by the International Rescue Committee indicated 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

Congress included a provision in the 2010 Dodd-Frank Wall Street 

Reform and Consumer Protection Act

In January 2015, the United 

Nations (UN) reported that the momentum created by the defeat of M-23, 

an illegal armed group, in November 2013 failed to translate into 

significant gains in security and stability in 2014 in eastern DRC. The UN 

also reported that while there has been progress on traceability and due 

diligence efforts concerning minerals produced in the DRC, smuggling 

continues, and that elements of the Congolese army and some armed 

groups remain involved in the minerals trade.

2 (hereafter referred to as the DoddFrank Act, or the act) that addressed the trade in “conflict minerals”—

tantalum, tin, tungsten, and gold.3

 1

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

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

Democratic Republic of the Congo, 

Section 1502 of the act directed 

GAO-10-1030 (Washington, D.C.: Sept. 30, 2010). 

2

Pub. L. No. 111-203, § 1502. 124 Stat. 1376, 2213-18.

3

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, cassiterite, and 

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

processed. 

Letter
Page 2 GAO-15-561 Congo Conflict Minerals

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. 

For example, Section 1502(b) of the act required SEC, in consultation 

with State, to promulgate disclosure and reporting regulations regarding 

the use of conflict minerals from the DRC and adjoining countries. SEC 

adopted its conflict minerals disclosure rule in August 2012.4 The act also 

required State, in consultation with USAID, to submit to appropriate 

congressional committees a conflict minerals strategy to address the 

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

minerals, and commercial products.5 In addition, the act 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 to report annually, beginning in 2011, on the rate of sexual 

violence in war-torn areas of the DRC and adjoining countries, among 

other things.6

This report examines (1) company disclosures filed with SEC for the first 

time in 2014 in response to the SEC conflict minerals disclosure rule, (2) 

State and USAID actions related to the U.S. conflict minerals strategy in 

the DRC region, and (3) any new information on the rate of sexual 

violence in eastern DRC and three adjoining countries—Burundi, 

Rwanda, and Uganda—that has become available since we issued our 

2014 report.

To address our objectives, we analyzed documents and data and 

interviewed officials from State, USAID, SEC, Commerce, 

nongovernmental organizations (NGO), industry, and international 

organizations, including several offices within the United Nations. To 

examine company disclosures filed with SEC in 2014 in response to the 

 4

Conflict Minerals, 77 Fed. Reg. 56,274, (Sept. 12, 2012) (codified at 17 C.F.R. § 

240.13p-1).

5

See Pub. L. No. 111-203, § 1502(c). Section 1502 of the act defines “appropriate 

congressional committees” to mean the Committee on Appropriations, the Committee on 

Foreign Affairs, the Committee on Ways and Means, and the Committee on Financial 

Services of the House of Representatives, and the Committee on Appropriations; the 

Committee on Foreign Relations; the Committee on Finance; and the Committee on 

Banking, Housing, and Urban Affairs of the Senate.

6

Pub. L. No. 111-203, § 1502(d).
Page 3 GAO-15-561 Congo Conflict Minerals

SEC rule, we downloaded Specialized Disclosure reports and Conflict 

Minerals Reports from SEC’s publically available Electronic Data 

Gathering, Analysis, and Retrieval (EDGAR) database. We randomly 

sampled 147 reports from a population of 1,324 to create estimates 

generalizable to the population of all companies that filed. All estimates 

based on our sample have a margin of error of plus or minus 10 

percentage points or less at the 95 percent confidence level. We 

determined that the EDGAR database was sufficiently reliable for 

identifying the universe of filings on July 31, 2014. We reviewed the 

Dodd-Frank Act and the requirements of the SEC disclosure rule to 

develop a questionnaire that guided our data collection and analysis of 

the filings. We also attended an industry conference on conflict minerals 

and spoke with company representatives to obtain additional 

perspectives. We traveled to the DRC, Burundi, and Rwanda to conduct 

field work. We met with a range of stakeholders, including NGOs, 

contractors, international organizations, and private sector

representatives, and visited three conflict minerals sites—a tantalum mine 

in the DRC, a tin mine in Rwanda, and a gold mine in Burundi—to 

observe operations and artisanal mining activities.7

We conducted this performance audit from September 2014 to August 

2015 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.

For a complete 

description of our scope and methodology, see appendix I.

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.

 7

Artisanal mining is a form of mining that is characterized by a lack of mechanization or 

capital investment.

Background

Brief History of Conflict in 

the DRC and the Region
Page 4 GAO-15-561 Congo Conflict Minerals

Figure 1: Map of the Democratic Republic of the Congo with Provinces and Adjoining Countries

Note: According to USAID, the DRC recently rolled out a decentralization scheme that has changed 

the number of provinces from 11 to 26.
Page 5 GAO-15-561 Congo Conflict Minerals

Since its independence in 1960, the DRC has undergone political 

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

DRC has continued to be plagued by violence, often perpetrated against 

civilians by illegal armed groups and some members of the Congolese 

national military. 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, which were perpetrated by armed groups and some 

members of the Congolese national military.

Some of the adjoining countries in the region have also experienced 

recent turmoil, which has led to flows of large numbers of refugees and 

internally displaced persons into the DRC.8 The United Nations High 

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

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

over 120,000 refugees from other countries, and around 2.6 million

internally displaced persons living in camps or with host families in the 

DRC.

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, and 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 used by the 

electronics industry.

As we reported in 2013, conflict minerals are mined in various locations 

around the world. For example, tin is predominantly mined in China, 

Indonesia, Peru, and Bolivia, as well as in the DRC, while tantalum is 

reportedly predominantly mined in areas such as Australia, Brazil, and 

 8

According 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.

Uses of Conflict Minerals
Page 6 GAO-15-561 Congo Conflict Minerals

Canada. Gold, however, is mined in many different countries, including 

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, stating that U.S policy is 

to engage with governments working for peace and security throughout 

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

working to destabilize the country.9 In July 2010, Congress passed the 

Dodd-Frank Act, of which Section 1502 included several provisions 

concerning conflict minerals in the DRC and adjoining countries.10

 9

Pub. L. No. 109-456, § 102(14), 120 Stat. 3384.

The act 

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

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

10Pub. L. No. 111-203, § 1502.

U.S. Government 

Response to Conflict

in the DRC
Page 7 GAO-15-561 Congo Conflict Minerals

Source: GAO analysis. | GAO-15-561

As we have previously reported, SEC, State, USAID, and Commerce 

have each taken steps to address the provisions of the act.

Dodd-Frank Act Provisions Concerning Conflict Minerals in the 

Democratic Republic of the Congo and Adjoining Countries

• 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 the Securities and Exchange 

Commission (SEC), in consultation with the Department of State 

(State), to promulgate disclosure and reporting regulations 

regarding the use of conflict minerals from the DRC and adjoining 

countries.

• Section 1502(c) requires State and the U.S. Agency for 

International Development (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 the Department of Commerce report, 

among other things, a listing of all known conflict mineralsprocessing facilities (smelters and refiners) worldwide.
Page 8 GAO-15-561 Congo Conflict Minerals

SEC issued its conflict minerals disclosure rule in August 201211 in 

response to Section 1502(b) of the Dodd-Frank Act, which required that 

SEC promulgate disclosure and reporting regulations regarding the use of 

conflict minerals from the DRC and adjoining countries by April 2011.12 In 

its summary of the rule, SEC noted that to accomplish the goal of helping 

to end the human rights abuses in the DRC caused by the conflict, 

Congress chose to use the securities laws disclosure requirements to 

bring greater public awareness of the source of companies’

13 conflict 

minerals and to promote the exercise of due diligence on conflict mineral 

supply chains.14

In the SEC adopting release, SEC noted that it understood Congress’s 

main purpose in doing so was to attempt to inhibit the ability of armed 

groups in the DRC and adjoining countries to fund their activities by 

exploiting the trade in conflict minerals. According to SEC, Congress’s 

objective was to promote peace and security, and reducing the use of 

such conflict minerals was intended to help reduce funding for the armed 

groups contributing to the conflict and thereby put pressure on such 

groups to end the conflict. SEC also indicated that one of the cosponsors 

of the provision noted that the provision would “enhance transparency”

 1177 Fed. Reg. 56,274.

12The term “adjoining country” is defined in Section 1502(e)(1) of the Act as a country that 

shares an internationally recognized border with the DRC, which included Angola, 

Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, 

Tanzania, Uganda, and Zambia at the time that SEC issued its conflict minerals disclosure 

rule. Pub. L. No. 111-203, § 1502. For the purposes of the conflict minerals disclosure 

rule, SEC refers to these countries as “Covered Countries.”

13The rule uses the term “issuers.” As adopted, the final rule applies to any issuer that files 

reports with SEC under Section 13(a) or Section 15(d) of the Securities Exchange Act of 

1934 (15 U.S.C. §§ 78m(a) and 78o(d)) and uses conflict minerals that are necessary to 

the functionality or production of a product manufactured or contracted by that issuer to be 

manufactured. For the purposes of our report, we refer to those issuers affected by the 

rule as “companies.”

14The Organisation for Economic Co-operation and Development defines “due diligence”

as an ongoing, proactive, and reactive process through which companies can ensure that 

they respect human rights and do not contribute to conflict. Due diligence can also help 

companies ensure that they observe international law and comply with domestic laws, 

including those governing the illicit trade in minerals and UN sanctions. Risk-based due 

diligence refers to the steps companies should take to identify and address actual or 

potential risks in order to prevent or mitigate adverse impacts associated with their 

activities or sourcing decisions.

SEC Promulgated Conflict 

Minerals Disclosure 

Rule in 2012
Page 9 GAO-15-561 Congo Conflict Minerals

and “also help American consumers and investors make more informed 

decisions.”15

Companies are required to file a Specialized Disclosure report (Form SD) 

if they manufacture or contract to manufacture products that contain 

conflict minerals necessary to the functionality or production of the 

products and, as applicable, file a Conflict Minerals Report. The form 

provides general instructions to companies for filing the conflict minerals 

disclosure and specifies the information that their Conflict Minerals 

Reports must include. Companies were required to file under the rule for 

the first time by June 2, 2014, and annually thereafter on May 31.16

In 2011, State and USAID developed the U.S. Strategy to Address the 

Linkages between Human Rights Abuses, Armed Groups, Mining of 

Conflict Minerals and Commercial Products. The strategy includes five 

objectives:

1. Promoting an Appropriate Role for Security Forces. U.S. efforts under 

this objective aim to end the commercial role of the DRC security 

forces in the minerals trade and to make the security forces more 

effective within their appropriate, limited role in monitoring and 

securing trade.

2. Enhance Civilian Regulation of the DRC Minerals Trade. U.S. efforts 

under this objective will aim to increase the capacity of DRC civilian 

authorities involved in overseeing the minerals trade, particularly in 

the east.

3. Protect Artisanal Miners and Local Communities. U.S. efforts under 

this objective will aim to reduce the vulnerability of men and women in 

local communities directly and indirectly engaged in the mining sector.

4. Strengthen Regional and International Efforts. U.S. efforts under this 

objective aim to support the implementation and coordination of 

national, regional, and international efforts to promote monitoring, 

certification, and traceability—particularly the Great Lakes regional 

 1577 Fed. Reg. 56,274.

16The first filing date was set for June 2, 2014, because May 31, 2014 occurred on a 

weekend. As explained in the SEC adopting release published in the Federal Register, if 

the deadline for filing the conflict minerals disclosure report occurs on a weekend, or a 

holiday on which SEC is not open for business, then the deadline shall be the next 

business day. 

State and USAID Developed 

U.S. Conflict Minerals

Strategy in 2011
Page 10 GAO-15-561 Congo Conflict Minerals

initiative—as well as the harmonization of due diligence guidance 

developed in various forums.

5. Promote Due Diligence and Responsible Trade through Public 

Outreach. U.S. efforts will aim, through public outreach, to encourage 

all stakeholders to take steps at the local, regional, and international 

level to promote the responsible trade in minerals.

Following our June 2014 report,17 Commerce issued a list of all known 

conflict minerals-processing facilities worldwide in September 2014.18 We 

reported in June 2014 that Commerce had not yet fulfilled its mandate 

under the act to report, among other things, a list of all known conflict 

minerals-processing facilities worldwide to appropriate congressional 

committees. We also recommended that the Secretary of Commerce 

provide to Congress a plan that outlines the steps, with associated time 

frames, to develop and report the required information about smelters and 

refiners of conflict minerals worldwide. As of July 2015, GAO was

reviewing Commerce’s related actions to assess its progress toward 

implementing the recommendation.

 17GAO, Conflict Minerals: Stakeholder Options for Responsible Sourcing Are Expanding, 

but More Information on Smelters Is Needed, GAO-14-575 (Washington D.C.: June 26, 

2014).

18As of June 2015, the list was accessible online at 

http://www.ita.doc.gov/td/forestprod/DOC-ConflictMineralReport.pdf.

Commerce Issued List of 

Known Conflict MineralsProcessing Facilities in 

September 2014
Page 11 GAO-15-561 Congo Conflict Minerals

Companies filed for the first time in response to the SEC rule in 2014 on 

conflict minerals used in calendar year 2013. As we previously reported, 

SEC adopted the final conflict minerals disclosure rule on August 22, 

2012.19 As adopted, the final rule applies to any company that files 

reports with SEC under Section 13(a) or Section 15(d) of the Securities 

Exchange Act of 193420 and uses conflict minerals that are necessary to 

the functionality or production of a product manufactured or contracted by 

that company to be manufactured.21 The SEC conflict minerals disclosure 

rule details a process for companies to follow, as applicable, to comply 

with the rule. Broadly, the process falls into three steps that require a 

company to (1) determine whether the rule applies to it; (2) conduct a 

reasonable country of origin inquiry concerning the origin of conflict 

minerals used; and (3) exercise due diligence, if appropriate, to determine 

the source and chain of custody of conflict minerals used. Figure 2 

depicts SEC’s flowchart summary of the conflict minerals disclosure 

rule.22

 19According to SEC, when SEC proposes or adopts a set of rules, often those rules are 

contained in a single document, called a proposing release or adopting release.

2015 U.S.C. §§ 78m(a) and 78o(d).

2177 Fed. Reg. 56,274.

22SEC notes that the flow chart is intended merely as a guide and that companies should 

refer to the rule text and the preamble’s narrative description for the requirements of the 

rule. While our discussion in this section is guided by the SEC flowchart, for the purposes 

of this report, we do not elaborate on every element in the flowchart. 

First Company Filings 

in Response to the 

SEC Rule Are Fewer 

Than SEC Estimated 

and Provide Limited 

Insights Regarding 

Country of Origin and 

Chain of Custody

Companies Filed for the 

First Time in Response to 

the SEC Rule in 2014 on 

Conflict Minerals Used in 

2013
Page 12 GAO-15-561 Congo Conflict Minerals

Figure 2: SEC Flowchart Summary of the Conflict Minerals Disclosure Rule
Page 13 GAO-15-561 Congo Conflict Minerals

Step 1: Determine Applicability of the Conflict Minerals Disclosure Rule

A company is subject to the rule if, as step 1 of figure 2 indicates, the 

company files reports with SEC under Section 13(a) or 15(d) of the 

Exchange Act and conflict minerals are necessary to the functionality or 

production of a product manufactured or contracted by that company to 

be manufactured. If a company does not meet this definition, it is not 

required, under the conflict minerals rule, to take any action, make any 

disclosures, or submit any reports. If, however, a company meets this 

definition, the company moves to step 2 of figure 2 (discussed later) and 

must file a Form SD.

The number of companies that filed Form SDs in 2014—1,321—was 

substantially lower than SEC’s estimate of 6,000 companies that could 

possibly be affected by the rule. In its rule proposal, SEC had estimated 

that approximately 6,000 companies could possibly be affected by the 

rule by estimating the number and types of businesses that SEC staff 

believed may manufacture or contract to manufacture products with 

conflict minerals necessary to the functionality or production of those 

products. According to an SEC official, this estimate was intentionally 

overly inclusive, was not an expectation, and was provided to satisfy the 

requirements of the Paperwork Reduction Act.23

Our analysis of a sample of 2014 Form SD filings indicated that an 

estimated 87 percent of the companies that filed were domestic, while an 

estimated 13 percent were foreign.24

 23For the purpose of the Paperwork Reduction Act of 1995, the Commission was required 

to estimate the number of companies that could be affected by the collection of 

information requirements of the rule. Pub. L. No. 104-13, 109 Stat. 163 (codified at 44 

U.S.C. §§ 3501-3520).

Also, while not all of the companies 

in our sample identified which conflict minerals they used in calendar year 

2013, as there was no requirement in the rule to do so, of those 

companies that did, about 58 percent reported using tin, 43 percent 

reported using tantalum, 39 percent reported using tungsten, and 44 

percent reported using gold (see fig. 3).

24Unless otherwise noted, all estimates of percentages have a margin of error of no more 

than plus or minus 10 percentage points.

Number of Companies 

Was Lower than SEC 

Estimated; Most

Were Domestic
Page 14 GAO-15-561 Congo Conflict Minerals

Figure 3: Percentage of Companies That Reported in Response to the SEC Conflict 

Minerals Disclosure Rule in 2014 That They Used Conflict Minerals in Calendar Year 

2013

Note: this percentage breakdown is based on our analysis of company filings from the SEC database. 

All estimates of percentages have a margin of error of no more than plus or minus 10 percentage 

points.

Step 2: Conduct a Reasonable Country of Origin Inquiry (RCOI) 

Regarding the Origin of Conflict Minerals

The sample of filings in 2014 that we reviewed indicates that 99 percent 

of companies conducted a country-of-origin inquiry and most companies 

reported that they were unable to determine the country of origin of 

conflict minerals they had used in 2013. Company representatives we 

interviewed cited difficulties in obtaining information from suppliers. If a 

company determines that it is subject to the SEC conflict minerals 

disclosure rule, the company is required to conduct a reasonable country 

of origin inquiry regarding the origin of conflict minerals it used and 

disclose its determination in a Form SD (illustrated by step 2.1 of fig. 2). 

The rule does not prescribe the specific actions that are required for an 

RCOI, noting that it will depend on each company’s facts and 

circumstances. However, the rule provides general standards: A company 

must conduct an inquiry regarding the origin of conflict minerals it used 

that is reasonably designed to determine whether any of those conflict 

minerals originated in the Covered Countries or are from recycled or 

Company Filings in 2014 

Indicate Companies 

Performed Country-ofOrigin Inquiry but Provided 

Limited Insights Regarding 

Country of Origin of 

Conflict Minerals Used, 

Citing Difficulty Obtaining 

Information From 

Suppliers
Page 15 GAO-15-561 Congo Conflict Minerals

scrap sources, and must conduct the inquiry in good faith.25

According to our analysis of all companies in our sample that filed a Form 

SD in 2014, an estimated

Moreover, 

the rule recognizes that a company, after conducting an RCOI, may not 

know whether conflict minerals it used originated from a Covered 

Country. For example, the rule explains that step 3 can be triggered by 

the determination that the company has a reason to believe that its 

necessary conflict minerals may have originated in the Covered Countries 

and may not have come from recycled or scrap sources.

• 67 percent reported that they were unable to determine the country of 

origin,

• 4 percent reported that conflict minerals came from Covered 

Countries,

• 24 percent reported that conflict minerals did not originate in Covered 

Countries,

• 2 percent reported that conflict minerals came from scrap or recycled 

sources, and

• 3 percent did not provide a clear determination.

In our analysis of a sample of filings, an estimated 99 percent of 

companies that filed a Form SD reported conducting an RCOI. Almost all 

(96 percent) of the companies reported that they conducted a survey of 

their suppliers to try to obtain information about whether they used conflict 

minerals, the country of origin of those conflict minerals, and the 

processor of the conflict minerals. We did not systematically analyze how 

companies conducted their supplier surveys, but a few of the Form SDs 

that we reviewed and some company representatives we spoke with 

indicated that they used a supplier survey and industry template to 

conduct their RCOIs. For example, one company reported that its method 

for determining the country of origin of its minerals was to conduct a 

supply chain survey with direct suppliers using a template developed by 

an industry association. Another company reported contacting suppliers 

 25Covered Countries are the DRC and countries that share an internationally recognized 

border with the DRC, which included Angola, Burundi, Central African Republic, the 

Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia at the time 

that SEC issued its conflict minerals rule.
Page 16 GAO-15-561 Congo Conflict Minerals

and using an industry survey template–the Conflict Minerals Reporting 

Template–from the Conflict-Free Sourcing Initiative, an industry 

association. In our analysis, an estimated 47 percent of companies 

reported that they received responses from the suppliers they surveyed. 

Nineteen companies in our sample reported that they had 100 percent 

response rates from their suppliers, but 12 of them were unable to 

determine the source of the conflict minerals. Four reported that they 

were able to determine that conflict minerals they used did not come from 

Covered Countries, while1 was able to determine that conflict minerals it 

used came from Covered Countries.26 Representatives of some 

companies that we spoke with told us that they received information from 

suppliers that was incomplete, limiting their ability to determine the source 

and chain of custody of the conflict minerals they used in 2013. As we 

reported in July 2013, a company’s supply chain can involve multiple tiers 

of suppliers.27 As a result, a request for information from a company could 

go through many suppliers, as figure 4 illustrates, delaying the 

communication of information to the company. For example, as we 

previously reported, companies required to report under the rule could 

submit the inquiries to their first-tier suppliers.28

 26Two of the companies that reported getting a100 percent response rate did not provide 

information about whether or not they were able to determine the source of conflict 

minerals they had used.

Those suppliers could 

either provide the reporting company with sufficient information or initiate 

the inquiry process up the supply chain, such as by distributing the 

inquiries to suppliers at the next tier—tier 2 suppliers. The tier 2 suppliers 

could inquire up the supply chain to additional suppliers, until the inquiries 

arrived at the smelter. Smelters could then provide the suppliers with 

information about the origin of the conflict minerals. Figure 4 illustrates 

the flow of information through the supply chain.

27GAO, SEC Conflict Minerals Rule: Information on Responsible Sourcing and Companies 

Affected, GAO-13-689 (Washington D.C.: July 18, 2013).

28Ibid.
Page 17 GAO-15-561 Congo Conflict Minerals

Figure 4: Simplified Conflict Minerals Supply Chain Showing Tiers of Suppliers

Representatives of some companies that we spoke with told us that they 

were making efforts to address concerns about the lack of information on 

the country of origin of conflict minerals they had used. For example, one 

representative told us that in the future the company plans to include in all 

new and renewing contracts a conflict minerals clause that will require its 

suppliers to source only conflict-free minerals, leveraging continuing 

business negotiations with its suppliers and adding downward pressure 

for suppliers to source responsibly from the region. Another company’s 

representative told us that the company would alter its outreach strategies 

to contact suppliers sooner and more frequently during the reporting 

process.

The rule requires a company that determines that, based on its RCOI,

conflict minerals it used (1) did not originate in the Covered Countries or 

(2) came from recycled or scrap sources, to disclose in its Form SD its 

determination and briefly describe the RCOI it used in reaching the 

determination and the results of the inquiry (illustrated in step 2.3 of fig.

2). As indicated above, an estimated 26 percent of all companies that 

filed a Form SD reported in these two categories. While we did not 

individually analyze each company’s description of method of RCOI in 

this group, as mentioned earlier, an estimated 96 percent of the 

companies in our sample that conducted an RCOI reported using supplier

surveys.
Page 18 GAO-15-561 Congo Conflict Minerals

Step 3: Exercise Due Diligence on the Source and Chain of Custody of 

Conflict Minerals Using a Nationally or Internationally Recognized 

Framework, if Available.

According to our analysis, the exercise of due diligence on the source and 

chain of custody of conflict minerals yielded little or no additional 

information, beyond the RCOI, regarding the country of origin of conflict 

minerals or whether the conflict minerals used in 2013 in products by 

companies benefited or financed armed groups in the Covered 

Countries.29 According to the SEC rule, based on a company’s RCOI, if a 

company knows that conflict minerals it used originated in the Covered 

Countries or has reason to believe that they may have originated in the 

Covered Countries and may not have come from recycled or scrap 

sources, the next step is to exercise due diligence using a nationally or 

internationally recognized due diligence framework, if such a framework is 

available for the necessary conflict minerals (step 3.1).30

• Majority of companies exercised due diligence and most maintained 

the determination that they could not identify origin of conflict 

minerals. According to our analysis, about 92 percent of the 

companies mentioned the OECD framework in connection with their 

 29We asked SEC staff to define “source and chain of custody of conflict minerals” in the 

context of a company’s exercise of due diligence. SEC staff noted that the Commission 

did not define these terms and did not specifically address in its releases how chain of 

custody relates to benefitting or financing armed groups. However, as depicted in figure 2, 

exercise of due diligence on source and chain of custody is associated with a company’s 

ability to determine whether conflict minerals it used are not from covered countries or are 

from scrap or recycled (step 3.1); and whether those conflict minerals financed or 

benefitted armed groups (step 3.3).

30While SEC did not specifically mandate the framework to be used, the SEC adopting 

release noted that it appears the only nationally or internationally recognized due diligence 

framework presently available is the due diligence guidance approved by the Organisation 

for Economic Co-operation and Development (OECD). The 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. Organisation 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. 

Company Filings Indicate 

Companies Exercised Due 

Diligence but Most Were 

Unable to Determine 

Whether or Not Conflict 

Minerals Used Came 

From Covered Countries, 

or Whether They Financed 

or Benefited Armed 

Groups
Page 19 GAO-15-561 Congo Conflict Minerals

due diligence, while another 2 percent mentioned a framework other 

than the OECD framework.31 Notwithstanding, the results remained 

as indicated above in the discussion of RCOI.

32

• Companies unable to determine if conflict minerals benefited or 

financed armed groups in Covered Countries. As we indicated in the 

discussion of RCOI, an estimated 4 percent of the companies 

determined that the necessary conflict minerals used in their products 

originated from Covered Countries. However, according to our 

analysis, all of these companies disclosed that they conducted due 

diligence on the source and chain of custody of conflict minerals they 

used but none were able to determine whether such conflict minerals 

financed or benefitted armed groups during the reporting period (step 

3.3 of fig. 2).

That is, an estimated 

67 percent of all companies declared that they were unable to 

determine the country of origin of the conflict minerals in their 

products.

• SEC rule provides a temporary period during which companies can 

describe their products as “DRC conflict undeterminable.” The SEC 

rule allows a temporary period during which, if after exercising due 

diligence for source and chain of custody of conflict minerals used in 

their products, companies remain unable to determine the origin of 

conflict minerals used and whether those minerals financed or 

benefitted armed groups, those companies can describe their 

products as DRC conflict undeterminable (step 3.5 of fig. 2) in their 

 31We did not determine if or how the companies applied the five-step process of the 

OECD due diligence framework. 

32According to one report, companies’ discussions of their RCOI and OECD due diligence 

guidance often were combined in the Conflict Minerals Report. In the sample the report 

analyzed, the majority of companies that filed a CMR included the substance of their 

RCOI within their discussion of the OECD guidance. See Schulte Roth & Zabel, Conflict 

Minerals Reporting: A Review of Calendar Year 2013 Filings and Recommendations for 

Calendar Year 2014 Compliance. September 2014.
Page 20 GAO-15-561 Congo Conflict Minerals

Conflict Minerals Report (CMR).33 The temporary period is in place for 

2 years for all companies and 4 years for smaller reporting companies 

following the effective date of the rule. However, due to continuing 

litigation in a legal challenge to the conflict minerals rule, SEC staff 

has issued guidance stating, among other things, that companies are 

not required to use this label.34

 33As we reported in our July 2014 report, in 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). After the 

panel’s decision was issued, the SEC and intervenor in the case petitioned for rehearing.

While the court was considering the petitions, the full DC Circuit issued a decision in a 

separate case that spoke to a First Amendment issue. American Meat Institute v. U.S. 

Department of Agriculture, 760 F.3d 18 (D.C. Cir. 2014). As a result, in November 2014, 

the panel hearing the conflict minerals case issued an order granting rehearing and 

directing the parties to file supplemental briefs regarding the impact of the new decision.

Those briefs were filed in December 2014 and the court is currently in the process of 

reviewing the briefs.

See appendix II for additional 

information on this issue. Figure 5 depicts the SEC conflict minerals 

disclosure rule timeline. As we previously reported, SEC staff had 

indicated that they anticipated that most companies during the first 

year of filing would likely claim “DRC conflict undeterminable” in their 

disclosures. According to SEC staff, of the 1,321 companies that filed 

distinct Form SDs in 2014, 89 percent were larger companies, while 

smaller companies made up 11 percent of all companies that filed a 

Form SD.

34See National Association of Manufacturers, et al. v. SEC et al., No. 13-5252 (D.C. Cir. 

April 14, 2014) and Keith F. Higgins, Director, SEC Division of Corporation Finance, 

Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals 

Rule (Apr. 29, 2014), available at 

http://www.sec.gov/News/PublicStmt/Detail/PublicStmt/1370541681994.
Page 21 GAO-15-561 Congo Conflict Minerals

Figure 5: The Securities and Exchange Commission (SEC) Conflict Minerals Disclosure Rule Timeline

Note: Under the SEC rule, if the deadline for filing the conflict minerals disclosure report occurs on a 

weekend, or a holiday on which SEC is not open for business, then the deadline shall be the next 

business day.

According to SEC, the temporary period recognizes that company 

processes for tracing conflict minerals through the supply chain must 

develop further. After the temporary period described above, if in 

exercising due diligence the company was not able to determine whether 

the conflict minerals came from Covered Countries or financed or 

benefited armed groups in those countries, it must include in its CMR a 

description of those products as not having been found to be DRC conflict 

free.35

• Majority of companies should have filed conflict minerals report as an 

exhibit to their Form SDs. The rule requires a company that exercised 

due diligence on the source and chain of custody of conflict minerals it 

used to file a Conflict Minerals Report as an exhibit to its Form SD 

(step 3.3), when appropriate. According to our analysis, at least an 

estimated 71 percent of companies should have filed a CMR as an 

exhibit to their Form SDs. The CMR must also include an Independent 

 3577 Fed. Reg. 56,274.
Page 22 GAO-15-561 Congo Conflict Minerals

Private Sector Audit (IPSA) report.36 According to the SEC disclosure 

rule, the audit’s objective is for the auditor to express an opinion or 

conclusion as to whether the design of the company’s due diligence 

measures as set forth in the CMR, with respect to the period covered 

by the report, is in conformity with, in all material respects, the criteria 

set forth in the nationally or internationally recognized due diligence 

framework used by the company, and whether the company’s 

description of the due diligence measures it performed as set forth in 

the CMR, with respect to the period covered by the report, is 

consistent with the due diligence process that the company 

undertook. Under the rule, for products that have not been found to be 

DRC Conflict Free, the companies are required to disclose, for those 

products, the facilities used to produce the conflict minerals, the 

country of origin of the minerals, and the efforts to determine the mine 

or location of origin.37

Companies that disclosed that conflict minerals came from covered 

countries indicated they are or will be taking action. Examples include the 

following:

• notify suppliers that the company intends to cease doing business 

with suppliers who continue to source conflict minerals from smelters 

that are not certified as conflict-free;

• include a conflict minerals clause in new or renewed contracts 

requiring suppliers to provide conflict minerals information on a 

prospective basis and identify alternative sources of conflict minerals 

if suppliers are found to be providing the company with minerals that 

support conflict in the Covered Countries;

• increase the number of surveyed suppliers; reach out earlier in the 

year, and direct suppliers to information and training resources;

 36In light of the ongoing legal case, SEC staff issued guidance on April 29, 2014, providing 

that an IPSA is not required unless a company voluntarily elects to describe any of its 

products as DRC conflict free in its Conflict Minerals report. Keith F. Higgins, Director, 

SEC Division of Corporation Finance, Statement on the Effect of the Recent Court of 

Appeals Decision on the Conflict minerals disclosure rule (Apr. 29, 2014), available at 

http://www.sec.gov/News/PublicStmt/Detail/PublicStmt/1370541681994.

37Pursuant to SEC guidance issued in response to ongoing litigation on April 29, 2014, 

subject to further action taken by either SEC or a court, no company currently is required 

to describe its products as “DRC conflict free,” having “not been found to be ‘DRC conflict 

free,’” or “DRC conflict undeterminable.”
Page 23 GAO-15-561 Congo Conflict Minerals

• participate in the Conflict-Free Sourcing Initiative, an industry 

association effort, to define best practices and induce smelters and 

refiners to adopt socially responsible business practices; and

• address, as appropriate, complaints or concerns expressed through 

grievance mechanisms.

State and USAID officials reported that they are implementing the U.S. 

conflict minerals strategy (the strategy) they submitted to Congress in 

2011 through specific actions that address the five key objectives of the 

strategy. Both State and USAID officials in Washington and the region 

reiterated that the strategy and its five key objectives remain relevant 

although years have passed since the strategy was developed. In 

November 2014, we requested a consolidated list of the actions the 

agencies are taking under the strategy’s objectives. The information we 

received included actions by each agency, or its implementing partners, 

and status or results, where applicable, as shown in tables 1 through 5.38

 38The information on agencies or implementing partners, activities, and results under each 

of the five objectives is presented as reported to us by State and USAID. We did not 

evaluate whether the reported activities are relevant to the objectives under which they 

are reported.

State and USAID reported that some activities are associated with 

multiple objectives.

State and USAID 

Actions to Implement 

the U.S. Conflict 

Minerals Strategy 

Have Yielded Some 

Results, but 

Conditions Remain 

Difficult

State and USAID

Are Taking Action to 

Implement Strategy 

Objectives
Page 24 GAO-15-561 Congo Conflict Minerals

As we previously reported, some members of the security forces in the 

DRC, such as some members of the Congolese national military units,

are consistently and directly involved in human rights abuses against the 

civilian population in eastern DRC and are involved in the exploitation of 

conflict minerals and other trades. Some of the reported actions being 

undertaken by the International Organization for Migration (IOM), a 

USAID implementing partner, are helping to lessen the involvement of the 

military and increasing the role of legitimate DRC government 

stakeholders in mining areas (see table 1). For example, USAID reported 

that IOM has assisted with the planning and demilitarization of mine sites 

in eastern DRC through leading a multi-sector stakeholder process of 

mine validation to ensure that armed groups and criminal elements of the 

Congolese military are not active in eastern DRC mines.

Table 1: USAID-Reported Actions to Promote an Appropriate Role for Security Forces, as of April 2015 

Activities Status/results

• Validating conflict-free mine sites through DRC government 

(GDRC) led multi-stakeholder teams

• Planning for demilitarization of mine sites

• Providing regular and as-needed security analysis and 

reports assessing ongoing threats to and opportunities for 

conflict-free minerals supply chains

• As of July 2015, validated 140 mine sites in eastern DRC

• Planned and facilitated demilitarization of 2 mine sites in 

South Kivu

• Facilitated conflict resolution between large-scale mining 

titleholders in North and South Kivu

Legend: USAID = U.S. Agency for International Development; DRC = Democratic Republic of the Congo

Sources: Department of State and USAID. | GAO-15-561

Official Congolese agencies tasked with regulating the minerals trade 

have responsibilities that include collecting production and export figures. 

However, as we reported in 2010, U.S. and DRC officials, a foreign 

official, and industry representatives told us that their ability to carry out 

their duties is reportedly impeded by various factors such as weak 

capacity, volatile security, and poor infrastructure, among other things. 

USAID reported that it is undertaking a number of actions, through 

implementing partners, to enhance civilian regulation and traceability of 

the DRC minerals trade.

Promote an Appropriate

Role for Security Forces 

(Objective 1)

Enhance Civilian Regulation

of the DRC Minerals Trade 

(Objective 2)
Page 25 GAO-15-561 Congo Conflict Minerals

For example, USAID reported funding TetraTech, a technical services 

company, to (1) build the capacity for responsible minerals trade in the 

DRC, (2) strengthen the capacity of key actors in the conflict minerals 

supply chain, and (3) advance artisanal and mining rights. In addition, 

USAID indicated that it is funding IOM to support DRC infrastructure and 

regulatory reform. According to an IOM official we spoke with in the 

region, IOM also provides the DRC government with information on which 

mines should be suspended from the conflict-free supply chain based on 

safety and human rights violations. A USAID official and representatives 

of local human rights organizations we met with during our visit to North 

Kivu also told us that the implementation of traceability schemes is 

contributing to positive outcomes.

Traceability Mechanisms

Traceability mechanisms 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. Such 

initiatives in the Democratic Republic of the Congo 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-15-561
Page 26 GAO-15-561 Congo Conflict Minerals

Figure 6: A Bag of Tantalum Ore at a DRC Mine Being Prepared for “Tagging,” a 

Method to Trace Origin, and Export
Page 27 GAO-15-561 Congo Conflict Minerals

Figure 7: A Bag of Tin Ore at a Rwandan Mine Tagged for Export

For example, in some cases, according to USAID, local miners earn 

double the price for certified conflict-free minerals compared to noncertified illegal minerals, which is more than they would earn from 

smuggling. Table 2 shows actions USAID has taken to enhance civilian 

regulation of the DRC minerals trade.
Page 28 GAO-15-561 Congo Conflict Minerals

Table 2: USAID-Reported Actions to Enhance Civilian Regulation of the DRC Minerals Trade, as of April 2015 

Activities Status/results

• Supporting government of DRC ministries and multi-stakeholder 

structures in planning and piloting traceability schemes

• Leading multi-stakeholder process of mine validation to ensure that

armed groups are not active in the region

• Strengthening traceability mechanisms by:

1. Improving DRC institutions and understanding about due 

diligence and responsible mining practices 

2. Including civil society in training efforts

3. Improving governance and finance skills among mining 

cooperatives

4. Providing occupational health and safety training and gender 

awareness

• Assessing the current DRC Mining Code and providing 

recommendations that address loopholes and gaps related to 

artisanal mining

• Conducting field based scoping exercises with DRC mining officials 

and civil society representatives to examine due diligence and 

traceability schemes and the formalization of artisanal mining

• Assessing artisanal mining cooperatives and providing training

• Providing funding, along with State, to the International Peace 

Information Service (IPIS) for the DRC government mapping 

capacity building

• Providing funding to build capacity among ICGLR governments for 

a regional certification mechanism

• Constructing sales point infrastructure to facilitate government 

transparent monitoring and taxation of the sales between miners 

and traders

• Facilitated government of DRC planning and validation 

of over 140 mine sites involved with an industry 

traceability mechanism

• Efforts to improve existing traceability schemes and 

demonstrate that new systems are allowing competition 

to function in conflict-free traceability systems, 

benefiting artisanal miners, exporters, and DRC 

government services

• Improved the capacity of the International Conference 

on the Great Lakes Region (ICGLR) regional 

certification mechanism

Legend: State = Department of State; USAID = U.S. Agency for International Development; DRC = Democratic Republic of the Congo

Sources: State and USAID. | GAO-15-561

According to USAID, artisanal mining provides survival incomes to 

Congolese throughout the country but it is particularly significant in 

eastern DRC, where roughly 500,000 people directly depend on artisanal 

mining for their income. These miners work under very difficult safety, 

health, and security conditions and almost always within an illegal and 

illicit environment. Moreover, as we observed during our visits to the 

mines in the region, artisanal mining is a physically demanding activity 

requiring the use of rudimentary techniques and little or no industrial 

capacity (see figs. 8 and 9 for illustrations of artisanal miners at work).

Protect Artisanal Miners

and Local Communities 

(Objective 3)
Page 29 GAO-15-561 Congo Conflict Minerals

Figure 8: Artisanal Miners at a Tantalum Mine in the Democratic Republic of the 

Congo
Page 30 GAO-15-561 Congo Conflict Minerals

Figure 9: Artisanal Miners at a Gold Mine in Burundi

State and USAID reported several programs (shown in table 3), through 

their implementing partners, aimed at protecting artisanal miners and 

local communities and providing alternative livelihoods. For example, 

State reported that it funded an implementing partner, Heartland Alliance 

International (HAI), a service-based human rights organization, for antihuman-trafficking initiatives as well as to promote alternative livelihoods 

and improve workers’ rights in the artisanal mining sector. According to 

State, these efforts aimed to reduce the vulnerability of men and women 

in local communities. State officials reported some illustrative examples of 

success in promoting alternative livelihoods. For example, a woman who 

used to transport minerals, a physically demanding, low-paying job, 

attended one of HAI’s alternative livelihood trainings where she received 

a kit to sell fish. Today, she makes a better living from selling fish and is 

able to pay her children’s school fees without working in the mining 

sector, according to State officials. In addition, USAID has funded Pact, 

an implementing partner, to promote community conflict-mitigation and 

conflict minerals monitoring structures at local levels. State also 

supported Pact to build local capacity for monitoring security and human 

rights conditions and mineral traceability, and provide local artisanal 

mining communities with resources to monitor, record, and report on 

initiatives and human rights abuses. State indicated that its actions 
Page 31 GAO-15-561 Congo Conflict Minerals

through Pact also support enhancing civilian regulation of the minerals 

sector and strengthening regional and international cooperation, other 

objectives of the strategy.

Table 3: Reported Actions to Protect Artisanal Miners and Local Communities, as of April 2015

Agency or 

implementing partner Activities Status/results

State implementing 

partner

• Investing in the organizational and technical capacity 

of worker rights organizations

• Providing socio-economic support and alternative 

livelihood opportunities to exploited workers

• Strengthening systems to promote identification and 

remediation of labor law violations in the mining 

sector at the local, regional, and international levels

• Strengthening the organizational and technical 

capacity of four mining cooperatives

• Miners reported increased capacity to report 

abuses, adopt nonviolent strategies to 

combat human rights violations, and to 

access legal assistance

• Sensitized 1,394 persons on abuses and 

human rights violations in the mining sector

• Directly raised the awareness of 3,538 

individuals from North and South Kivu about 

worker rights in the mining sector, and 

thousands of others via radio

• Mining cooperatives increased their technical 

and organizational capacities, including 

development and/or maintenance of 

standard accounting records, adoption of 

national and international organizational 

guidelines and protocols, commitment of 

cooperatives’ leadership to improve working 

conditions, and the establishment of new 

organizational structures that promote 

efficiency

• Improved competitiveness of cooperatives in 

the local economic market
Page 32 GAO-15-561 Congo Conflict Minerals

Agency or 

implementing partner Activities Status/results

State and USAID 

implementing partner

USAID implementing 

partner

• Providing baseline studies of mining

• Providing alternative livelihoods, including village 

savings and loan associations to women and men 

involved in artisanal mining

• Fostering a grass-roots approach aimed at 

sustainably increasing security, strengthening 

human rights protections, moving toward mine 

demilitarization, and reducing corruption in the DRC 

and Rwanda

• Strengthening the capacity of local government 

employees, including their capacity to prevent 

human rights abuses, and to mitigate conflict, in 

efforts to promote traceability

• Implementing partner commissioned to conduct an 

in-depth assessment of human trafficking —

including both sex and labor trafficking—in mining 

communities to address an information gap 

regarding the prevalence of human trafficking in 

mining areas

• Built local capacity for monitoring security 

and human rights conditions and mineral 

traceability, including providing local 

artisanal mining communities with resources 

to monitor, record, and report on initiatives, 

security challenges, human rights abuses 

and perpetrators, and corruption and to 

enable local authorities to take appropriate 

action to protect mining communities

• Provided key information to civilians in North 

and South Kivu about mineral sector 

governance and its link to conflict, increasing 

understanding of traceability and certification 

systems

• Findings have been made available and 

shared with U.S. government agencies, the 

government of the DRC, civil society actors, 

UN agencies, and donors. USAID will use 

the assessment to improve the design and 

implementation of programs related to the 

minerals trade, economic recovery, and antihuman trafficking

Legend: State = Department of State, USAID = U.S. Agency for International Development, DRC = Democratic Republic of the Congo, UN = United 

Nations

Sources: State and USAID | GAO-15-561

In our July 2012 report, we provided a description of regional and global 

initiatives being undertaken by various stakeholders that may facilitate 

responsible sourcing of conflict minerals in the DRC region.39

 39GAO, Conflict Minerals Disclosure Rule: SEC’s Actions and Stakeholder-Developed 

Initiatives, 

These 

included, among others, efforts by the UN and International Conference 

on the Great Lakes Region (ICLGR). Objective 4 of the U.S. conflict 

minerals strategy calls for actions to strengthen regional and international 

efforts. USAID reported that it is working with TetraTech to achieve this 

goal. Specifically, USAID said it is working with TetraTech to build the 

capacity of the ICGLR, an intergovernmental organization. According to 

USAID, this effort supports the implementation and coordination of 

regional countries’ efforts to promote monitoring, certification, and 

traceability of mine sites. A TetraTech representative we met with in the 

region told us that TetraTech is also organizing workshops for educating 

and raising awareness about regional certification in ICGLR countries.

GAO-12-763 (Washington D.C.: July 16, 2012).

Strengthening Regional

and International Efforts 

(Objective 4)
Page 33 GAO-15-561 Congo Conflict Minerals

According to officials we interviewed from the United Nations 

Organization Stabilization Mission in the Democratic Republic of the 

Congo (MONUSCO), the ICGLR, and local officials, U.S. diplomacy has 

increased awareness and improved coordination about conflict minerals 

in the region; a situation described by some of the officials as the most 

effective State and USAID actions for conflict minerals in the region.

Table 4: Reported Actions to Help Strengthen Regional and International Efforts, as of April 2015

Agency or 

implementing partner Activities Status/results

USAID implementing 

partner: TetraTech

• Working to establish an independent auditor function 

for the International Conference on the Great Lakes 

Region (ICGLR)

• Support the initial third-party audits component of 

the ICGLR Regional Certification Mechanism

• Assessed the independent mineral chain 

audit function

• Currently drafting an implementation plan for 

the independent mineral chain audit function

• An ICGLR audit has been conducted in 

Rwanda

State and USAID • Engaging regional and international actors through 

diplomacy 

Legend: State = Department of State; USAID = U.S. Agency for International Development; DRC = Democratic Republic of the Congo

Sources: State and USAID. | GAO-15-561

State and USAID reported engaging in various efforts to reach out to 

industry associations, NGOs, international organizations, and regional 

entities to help promote due diligence and responsible trade in conflict 

minerals. For example, State and USAID reported that they leveraged 

private sector interest to establish the Public-Private Alliance for 

Responsible Minerals Trade (PPA) to support supply chain solutions to 

conflict minerals challenges in the region. The alliance includes State, 

USAID, and representatives from U.S. end-user companies, industry 

associations, NGOs, and ICGLR, among others. In addition, State is 

engaged with the Conflict-Free Sourcing Initiative (CFSI) and State and 

USAID both participate in the biannual OECD, UN Group of Experts 

(UNGOE), ICGLR forums. According to State and USAID officials, these 

efforts promote continued engagement with industry officials and civil 

society groups and encourage due diligence and strengthening of conflictfree supply chains. At a conference in Kinshasa, DRC, co-hosted by the 

OECD, UN Group of Experts, and the ICGLR in November 2014, we 

observed State and USAID officials outline their actions, outcomes, and 

next steps to conference participants. A USAID official in the region told 

us that teams of private sector executives, which State and USAID 

officials in the DRC and Rwanda helped to organize and host, have 

visited eastern DRC and Rwanda mining sites on several occasions, 

reinforcing the executives’ commitment to source minerals responsibly. 

Promote Due Diligence and 

Responsible Trade through 

Public Outreach (Objective 5)
Page 34 GAO-15-561 Congo Conflict Minerals

According to the USAID official, these efforts have resulted in a reduction 

in predatory taxes, contributions by exporters to social development, and 

increased focus on certification and traceability systems. Noting that visits 

to the DRC and some locations in Rwanda had been coordinated and led 

by State and USAID staff, a State official added that some private

companies had made independent contributions to community projects 

and other companies had been active in providing feedback on 

certification and traceability mechanisms.

Table 5: Reported Actions to Promote Due Diligence and Responsible Trade through Public Outreach, as of April 2015

Agency or 

implementing partner Activities Status/results

State and USAID 

Partners with the 

Public-Private Alliance 

for Responsible 

Minerals Trade (PPA)

• Providing funding and support to organizations 

working in the region to develop verifiable conflictfree supply chains

• Aligning chain of custody programs and practices

• Encouraging responsible sourcing and transparency

• Bolstering in-region civil society and government 

capacity

• Convening periodic stakeholder meetings to 

facilitate alignment among multiple initiatives across 

up-stream, smelters/refiners, and end-user 

companies 

• Raised $1.2 million from the private sector to 

support programs

• National Center for Development Support 

and Public Participation (a PPA program) 

supported civil society capacity to monitor 

transparency, implementation of an earlywarning system, and accountability of the 

mining sector in South Kivu province of the 

DRC

• Currently finalizing the scope of a grant to 

Save Act Mine (SAM), a Congolese nongovernmental organization (NGO), to support 

community efforts to report suspected 

conflict minerals smuggling activities in North 

and South Kivu

• Contributed to the direct engagement and 

involvement of 119 private sector end-user 

companies directly or through trade 

association memberships in understanding 

and promoting responsible sourcing, along 

with prominent NGOs, and the 12 nations of 

the International Conference of the Great 

Lakes Region (ICGLR)

State and USAID • Engaging with the private sector through the 

Conflict-Free Sourcing Initiative (CFSI), the 

Automotive Industry Action Group, and companies

• Engaging with international stakeholders, such as 

the United Nations Group of Experts (UNGOE), 

International Conference on the Great Lakes Region 

(ICGLR) and Organisation for Economic 

Cooperation and Development (OECD)

• Participant at CFSI conferences

• Participant OECD/ICGLR/UNGOE 

conferences

Legend: State = Department of State; USAID = U.S. Agency for International Development; DRC = Democratic Republic of the Congo

Sources: State and USAID. | GAO-15-561
Page 35 GAO-15-561 Congo Conflict Minerals

Although State and USAID officials have provided some examples of 

results associated with their actions, the agencies face difficult operating 

conditions that complicate efforts to address the connection between 

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

We have described some of these challenges in our previous reports but, 

as we observed during our recent visit to the region, numerous 

challenges continue to exist. First, the mining areas in eastern DRC 

continue to be plagued by insecurity because of the presence and 

activities of illegal armed groups and some corrupt members of the 

national military. In 2010, we reported extensively on the presence of 

illegal armed groups, such as the Democratic Forces for the Liberation of 

Rwanda or Forces Democratiques de Liberation du Ruwanda (FDLR), 

and some members of the Congolese military and the various ways in 

which they were involved in the exploitation of the conflict minerals sector 

in eastern DRC.40 In 2013, the Peace and Security Cooperation 

Framework signed by 11 regional countries noted that eastern DRC has 

continued to suffer from recurring cycles of conflict and persistent 

violence.41 Although U.S. agency and Congolese officials informed us 

during our recent field-work in the region that a large number of mines 

had become free of armed groups (referred to as green mines),42

 40See 

MONUSCO officials we met with in the DRC also told us that armed 

groups and some members of the Congolese military were still active in 

other mining areas. Specifically, MONUSCO officials described two 

fundamental ways in which armed groups continued to be involved in 

conflict minerals activities: directly, by threatening and perpetrating 

violence against miners to confiscate minerals from them; and indirectly, 

by setting up checkpoints on trade routes to illegally tax miners and 

traders. As we noted in our 2010 report, U.S. agency and UN officials and 

others believe that the minerals trade in the DRC cannot be effectively 

monitored, regulated, or controlled as long as armed groups and some 

GAO-10-1030.

41Peace, Security and Cooperation Framework for the Democratic Republic of the Congo 

and the Region , signed in Addis Ababa (Feb. 24, 2013).

42For this report, we traveled to a tantalum mine in eastern DRC, which would have been 

impossible in 2010 during our last visit to the region, because of security concerns at that 

time.

State and USAID Face 

Difficult Conditions in 

Implementing the U.S. 

Conflict Minerals Strategy
Page 36 GAO-15-561 Congo Conflict Minerals

members of the Congolese national military continue to commit human 

rights violations and exploit the local population at will.43

As we reported in 2010, U.S. government officials and others have

indicated that weak governance and lack of state authority in eastern 

DRC constitute a significant challenge. As we noted then, according to 

U.N. officials, if Congolese military units are withdrawn from mine sites, 

civilian DRC officials will need to monitor, regulate, and control the 

minerals trade. We also noted that effective oversight of the minerals 

sector would not occur if civilian officials in eastern DRC continued to be 

under paid or not paid at all, as such conditions easily lead to corruption 

and lack of necessary skills to perform their duties. Evidence shows that 

this situation has not changed much. U.S. agencies and an implementing 

partner, as well as some Congolese officials, told us that there are 

insufficiently trained civilians to effectively monitor and take control of the 

mining sector. ICGLR officials we met with highlighted the importance of a 

regional approach to addressing conflict minerals and indicated that 

governments’ capacity for and interest in participating in regional 

certification schemes varies substantially, making it difficult to implement 

credible, common standards. Corruption continues to be a challenge in 

the mining sector. For example, a member of the UN Group of Experts 

told us that smuggling remains prolific and that instances of fraud call into 

question the integrity of traceability mechanisms. This official stated that 

tags used to certify minerals as conflict free are easily obtained and 

sometimes sold illegally in the black market. According to USAID, USAID 

is working to introduce a pilot traceability system to increase 

transparency, accountability, and competition in the legal artisanal mining 

sector. According to U.S. government officials and officials from local and 

civil society in the region that we met with, lack of state authority bolsters 

armed group activity and precludes public trust in the government.

Poor infrastructure, including poorly maintained or nonexistent roads, 

makes it difficult for mining police and other authorities to travel in the 

region and monitor mines for illegal armed group activity. In our 2010 

report, we reported that the minerals trade cannot be effectively 

monitored, regulated, and controlled unless civilian DRC officials, 

representatives from international organizations, and others can readily 

access mining sites to check on the enforcement of laws and regulations 

 43GAO-10-1030.
Page 37 GAO-15-561 Congo Conflict Minerals

and to ensure visibility and transparency at the sites.44 During our recent 

visit to the region, poor road conditions made travel to the mines very 

challenging (see fig. 10).45

Figure 10: Stuck Vehicle during a Visit by GAO Team to a Mine Site in Eastern DRC 

(November, 2014)

In addition, U.S. agencies cited the overall lack of an investor-friendly 

environment, including poor investment climate, arbitrary and excessive 

taxation and predatory government monitoring and enforcement, and the 

scarcity of basic services, such as water and electricity, as challenges 

that make it difficult for mining companies to conduct business, a 

fundamental issue that precludes economic development and makes it 

more difficult for U.S. agencies and contractors to conduct oversight and 

provide services. Also, a mine owner in eastern DRC that we met with 

 44GAO-10-1030.

45The mine owner told us that he paid for the road pictured in figure 10 to be constructed 

because no road to the mine existed and there was no public capacity to build one. 
Page 38 GAO-15-561 Congo Conflict Minerals

cited a range of challenges to conducting business in the region, including 

lack of access to financing, poor security, and inadequate infrastructure.

Since we last reported, in June 2014, results from three new populationbased surveys related to sexual violence in eastern DRC have been 

published, one of which provides a basis for comparison with results of an 

earlier survey of sexual violence in the DRC.46 The Dodd-Frank Act 

mandated GAO to report annually, beginning in 2011, on the rate of 

sexual violence in war-torn areas of the DRC and adjoining countries.47

No new population-based surveys related to sexual violence in Uganda, 

Rwanda, or Burundi have been published since our last report, but some 

surveys in these countries are underway or being planned. Some new 

additional case file data on sexual violence are available for some of 

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

sexual violence are not suitable for estimating an overall rate of sexual 

violence.48

We identified three new population-based surveys related to sexual 

violence in eastern DRC that have been published since June 2014: (1) a 

Demographic and Health Survey (DHS) conducted by the DRC Ministry of 

Planning with technical assistance from ICF International,49

 46GAO, Conflict Minerals: Stakeholder Options for Responsible Sourcing are Expanding, 

but More Information on Smelters is Needed, 

(2) a USAIDfunded survey conducted by a U.S.-based monitoring and evaluation firm 

(Social Impact) and (3) a survey co-produced by the Harvard 

Humanitarian Initiative, a university-based research center, and the 

United Nations Development Program (UNDP). For the purposes of this 

report, we define eastern DRC as encompassing South Kivu, North Kivu, 

and the Ituri District of Orientale Province. Population-based surveys for 

GAO-14-575 (Washington, D.C. June 26, 

2014).

47Pub. L. No. 111-203, § 1502(d)(1). 

48GAO, The Democratic Republic of 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).

49ICF International implements the 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.

Additional Information 

Available on Rate of 

Sexual Violence in 

Eastern DRC and 

Adjoining Countries 

since GAO’s June 

2014 Report

Three New PopulationBased Studies Provide 

Additional Data on Sexual 

Violence in the DRC; 

Additional Studies for 

Adjoining Countries Are 

Under Way or Planned
Page 39 GAO-15-561 Congo Conflict Minerals

Burundi and Rwanda are underway or planned by ICF International, 

which does not currently have plans to conduct another DHS for Uganda.

We previously reported that population-based surveys are more 

appropriate for estimating the rate of sexual violence than case file data 

because population based surveys are conducted using the techniques of 

random sampling and their results are generalizable.50

A Demographic and Health Survey of the DRC was published in 

September 2014, covering data collected from November 2013 to 

February 2014.

However, there 

are limitations and challenges to using such surveys to gather data on 

sexual violence and estimate the rate of such violence, particularly in 

eastern DRC. Examples of limitations include undercoverage caused by 

poor infrastructure and insecurity, which can limit access to some areas; 

and underreporting, as survey response rates partly depend on whether 

or not sexual violence victims are willing to discuss such difficult 

experiences. In addition, if large sample sizes are required, the result can 

be higher survey costs.

51 An ICF International analysis of the 2013-2014 survey 

data found that, in the DRC, 17 percent of women nationwide, ages 18-

49, reported they had experienced sexual violence in the 12-month period 

preceding the survey, while 29 percent reported they had experienced 

sexual violence at some point in their lifetime.52

 50

ICF International’s 

analysis also found that in North Kivu, 14 percent of women in that age 

group reported they had experienced sexual violence in the 12-month 

period preceding the survey while 30 percent reported they had 

experienced sexual violence at some point in their lifetime. In South Kivu, 

18 percent of women reported they had experienced sexual violence in 

the 12-month period preceding the survey, while 37 percent reported they 

had experienced sexual violence at some point in their lifetime. The DHS

GAO-11-702. 

51Ministry of Planning and Implementation of the Modern Revolution (MPSMRM), Ministry 

of Public Health (MSP), and ICF International. Democratic Republic of Congo 

Demographic and Health Survey 2013-14. Rockville, MD, 2014.

52Figures in the published September 2014 DHS report differ from those generated by ICF 

International. For the purposes of this review, ICF International identified sexual violence 

data that could be compared across time periods. According to ICF International, figures 

from the published DHS 2008 and 2014 reports for the DRC cannot be compared because 

the questions asked and the population interviewed for the two surveys differed. For 

example, the 2008 DHS interviewed females ages 18-49 while the 2014 DHS interviewed 

females ages 15-49. 

2014 Demographic and

Health Survey of the DRC
Page 40 GAO-15-561 Congo Conflict Minerals

study was designed to provide data for monitoring the population and 

health situation in the DRC, using indicators such as fertility, sexual 

activity, and family planning, among other things. The DRC Ministry of 

Planning conducted the survey with the support of the DRC Ministry of 

Public Health as well as several foreign governments; international, and 

nongovernmental organizations, including USAID; various UN agencies; 

and the World Bank.

The 2014 DHS survey of the DRC is the second such survey conducted 

by the DRC’s Ministry of Planning that has yielded nationwide information 

on sexual violence in the DRC, so it provides a basis for comparison over 

time. The first DHS survey was published in August 2008, and was 

conducted from January 2007 to August 2007.53

According to an analysis by ICF International, which compared estimates 

from the 2007 and 2013-2014 survey data, nationwide estimates of 

sexual violence decreased from 2007 to 2013-2014 for both the 12-month 

period preceding the surveys (28 percent to 17 percent) and the lifetime 

figures (36 percent to 29 percent). ICF International determined these 

differences to be statistically significant. For North Kivu, the rate of sexual 

violence reported by women in the 1-year period preceding the 2007 and 

2013-2014 surveys decreased from 30 percent in 2007 to 14 percent in 

2013-2014, which is also statistically significant, according to ICF 

International. For South Kivu, ICF International found no statistically 

significant difference in the rate of sexual violence reported by women in 

the 12-month period preceding the survey and at any point in their lives 

between the 2007 and 2013-2014 surveys. See table 6 for a summary of 

the comparisons.

According to ICF 

International’s analysis of the 2007 survey data, 28 percent of women 

nationwide, ages 18-49, reported having experienced sexual violence in 

the 12-month period preceding the survey, while 36 percent of women 

nationwide reported they had experienced sexual violence at some point 

in their lifetime.

 53Ministry of Planning and Macro International. Democratic Republic of the Congo 

Demographic and Health Survey 2007. Calverton, MD: Ministry of Planning and Macro 

International. 2008.
Page 41 GAO-15-561 Congo Conflict Minerals

Table 6: 2007 and 2013-2014 DHS Data on the Rates of Sexual Violence Reported by Women in the DRC, Ages 18-49, by 

Percentage

Geographic Area

Rate of Sexual Violence 

Reported in 2007 

(12-Month Period 

Preceding the Survey)

Rate of Sexual Violence 

Reported in 2013-2014 

(12-Month Period 

Preceding the Survey)

Rate of Sexual Violence 

Reported in 2007 

(Lifetime)

Rate of Sexual Violence 

Reported in 2013-2014 

(Lifetime)

South Kivu 20 18 32 37

North Kivu 30a 14a 43 30

Nationwide estimates 28a 17a 36a 29a

Source: ICF International analysis of DHS 2007 and 2013-2014 sexual violence data for the DRC. | GAO 15-561

Notes:

a

The change in the rate from 2007 to 2013-14 is statistically significant for that geographic area.

Data above are based on DHS questions asking whether sexual violence was perpetrated by the 

woman’s current or most recent spouse/partner and by a perpetrator other than the woman’s current 

or most recent spouse/partner. The data are not based on survey questions asking whether the 

women’s first experience of sexual intercourse was forced. “Lifetime” refers to whether a woman 

reported experiencing sexual violence at any point in her life. Figures in table have been rounded. 

The nationwide estimates include data for Orientale Province but do not provide estimates on the rate 

of violence for the Ituri District, located within Orientale Province.

A population-based survey, funded by USAID and conducted by the U.S.-

based organization Social Impact, on human-trafficked individuals, ages 

15 and older, in artisanal mining towns in South Kivu and North Katanga, 

found that 7.1 percent of women and 1.2 percent of men had experienced 

sexual violence in the previous year at the mining sites. The survey, 

published in August 2014, and covering data collected from April 2014 to 

May 2014, also found that the most common perpetrators of this violence 

were friends or acquaintances (identified as responsible for about onehalf of the attacks) and miners (identified as responsible for about onefifth of the attacks). The survey is intended to measure sexual violence in 

areas that have artisanal mines and included a sample of territories within 

eastern DRC and outside of eastern DRC. Because of this, survey results 

may not be generalizable to the population of eastern DRC.

A 2014 survey, co-produced by the Harvard Humanitarian Initiative and 

UNDP, of adult men and women, ages 18 and older, in the eastern DRC 

provinces of North and South Kivu and the Ituri District, found that 23 

percent of respondents had witnessed sexual violence being committed 

USAID-Funded Social Impact 

Survey of Eastern DRC

Harvard Humanitarian

Initiative / UNDP Survey

of Eastern DRC
Page 42 GAO-15-561 Congo Conflict Minerals

by armed groups on civilians since 2002.54 The survey also found that a 

total of 9 percent of respondents had witnessed sexual violence being 

committed by armed groups on civilians over the 12-month period prior to 

the survey.55

Although no new population-based surveys related to sexual violence in 

Uganda, Rwanda, and Burundi have been published since July 2014, 

population-based surveys are underway or planned by ICF International 

in Rwanda and Burundi. (Fig. 11 shows a timeline of population-based 

surveys for the DRC, Rwanda, Uganda, and Burundi since 2007). 

According to ICF International, data collection for a DHS for Rwanda is 

complete and it expects to publish the survey results by the end of 2015. 

ICF International said it has planned a DHS for Burundi in late 2015 and 

expects the report to be available in late 2016. ICF International said that 

discussions are underway to conduct another DHS for Uganda in 2016 

but it may or may not include questions related to sexual violence.

The survey was conducted between November 2013 and 

December 2013. According to the survey report, the survey was 

conducted to assess the population of eastern Congo’s perceptions, 

knowledge, and attitudes about peace, security, and justice, and aimed at 

providing results that were representative of the adult population of 

territories and major urban areas in eastern Congo. The interviewers 

asked respondents if they had witnessed sexual violence being 

perpetrated by armed groups on civilians, but did not explicitly ask 

whether the respondents had ever experienced sexual violence; therefore 

we found that the data cannot be used to estimate the rate of sexual 

violence in eastern DRC.

 54The survey provides a breakdown of the percentage of respondents who witnessed 

sexual violence being committed by armed groups on civilians since 2002, by province: 24 

percent for North Kivu, 29 percent for South Kivu, and 12 percent for the Ituri District of 

Orientale Province. 

55The survey provides a breakdown of the percentage of respondents who witnessed 

sexual violence being committed by armed groups on civilians over the 12-month period 

prior to the survey, by province: 14 percent for North Kivu, 8 percent for South Kivu, and 3 

percent for Ituri District of Orientale Province.

Additional Population Surveys 

of Adjoining Countries Under 

Way or Planned
Page 43 GAO-15-561 Congo Conflict Minerals

Figure 11: Timeline of Population-Based Surveys Estimating the Rate of Sexual Violence in Eastern DRC, Rwanda, Uganda, 

and Burundi

a

We recently identified the Uganda 2011 AIDS Indicator Survey as containing data on sexual violence 

in this country.

Since GAO’s June 2014 report, State and some UN agencies have 

provided additional case file data on instances of sexual violence in the 

DRC and adjoining countries. State’s annual country reports on human 

rights practices provided information pertaining to sexual violence in the 

following countries:56

• DRC. The state security force, rebel and militia groups, and civilians 

perpetrated widespread sexual violence. The United Nations 

registered 3,635 victims of sexual violence from January 2010 to 

December 2013. These crimes were often committed during attacks 

 56U.S. Department of State, Bureau of Democracy, Human Rights, and Labor, Country 

Reports on Human Rights Practices for 2014, accessed June 30, 2015, 

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 2014 Report
Page 44 GAO-15-561 Congo Conflict Minerals

on villages and sometimes as a tactic of war to punish civilians for 

perceived allegiances with rival parties or groups. The crimes 

occurred largely in the conflict zones in North Kivu province but also in 

provinces throughout the country.

• Burundi. Centre Seruka, a clinic for rape victims, reported an average 

of 135 new rape cases per month from January through September. 

Of that number, 68 percent were minors, and 17 percent were 

children under age five. Centre Seruka also reported approximately 

30 percent of its clients filed complaints, and 70 percent knew their 

aggressors.

• Rwanda. Domestic violence against women was common. Although 

many incidents remained within the extended family and were not 

reported or prosecuted, government officials encouraged the reporting 

of domestic violence, and the Rwanda National Police stated that 

reporting of such cases increased.

• Uganda. Rape remained a serious problem throughout the country, 

and the government did not consistently enforce the law. Although the 

government arrested, prosecuted and convicted persons for rape, the 

crime was seriously underreported, and authorities did not investigate 

most cases. Police lacked the criminal forensic capacity to collect 

evidence, which hampered prosecution and conviction. The 2013 

police crime report registered 1,042 rape cases throughout the 

country, of which 365 were tried. Of these, 11 convictions were 

secured, with sentences ranging from 3 years to life imprisonment, 11 

cases were dismissed; and 343 cases were still pending in court at 

year’s end.

In addition, some UN entities reported case file information on sexual 

violence in the DRC and Burundi, as described below:

• DRC. A March 2015 report of the Secretary-General on conflictrelated sexual violence showed that, from January 2014 to September 

2014, the United Nations Population Fund (UNFPA) recorded 11,769 

cases of sexual violence in the provinces of North Kivu, South Kivu, 

Orientale, Katanga, and Maniema. Of these cases, 39 percent were 

considered to be directly related to the dynamics of conflict, being 

perpetrated by arms bearers. The report also notes that, as in 2013, 

North Kivu and Orientale remain the provinces most affected by 
Page 45 GAO-15-561 Congo Conflict Minerals

conflict-related sexual violence, with 42 percent of all incidents taking 

place in Orientale.57

• DRC. MONUSCO reported in September 2014 that armed groups and 

national security forces continued to commit crimes of sexual 

violence. Between June 30, 2014, and September 25, 2014, it 

recorded 37 cases of sexual violence committed by armed groups and 

national security forces, 15 of which were committed by the armed 

forces of the Democratic Republic of Congo and 10 by Mayi-Mayi 

combatants from different groups. The report indicates that 18 of the 

37 cases of sexual violence occurred in North Kivu, South Kivu, and 

Orientale Provinces.58

• DRC. MONUSCO also recorded 61 cases of sexual violence in 

conflict during the reporting period of September 25, 2014 to 

December 30, 2014. MONUSCO reports that at least 30 women and 

31 children were victims of sexual violence, allegedly committed by 

armed groups and national security forces in eastern DRC.

59

• Burundi. UNFPA reports that it supported 3,203 survivors of sexual 

violence at care centers located in the areas of Seruka, Nturengaho, 

and Humara. In addition, 24 UNFPA-supported hospitals across six 

provinces in Burundi are also collecting sexual violence data. UNFPA 

reports that these hospitals provided medical support to 180 survivors 

in 2014.

As we previously reported, several factors make case file data unsuitable 

for estimating rates of sexual violence.60

 57UN Security Council, Report of the Secretary-General on Conflict-related Sexual 

Violence, S/2015/203 (New York, NY: March 23, 2015).

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 

in surveys, time frames, locales, and definitions of sexual violence may 

58UN Security Council, Report of the Secretary-General on the United Nations 

Organization Stabilization Mission in the Democratic Republic of Congo, S/2014/698 (New 

York, NY: Sept. 24, 2014). 

59UN Security Council, Report of the Secretary-General on the United Nations 

Organization Stabilization Mission in the Democratic Republic of Congo, S/2014/956 (New 

York, NY: Dec. 30, 2014).

60GAO-14-575. 
Page 46 GAO-15-561 Congo Conflict Minerals

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.

We provided a draft of this report to SEC, State, USAID, and Commerce 

for their review. Agencies provided technical comments, which we have 

incorporated as appropriate.

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 staff 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 IV.

Kimberly M. Gianopoulos

Director, International Affairs and Trade

Agency Comments 
Page 47 GAO-15-561 Congo Conflict Minerals

List of Addressees

The Honorable Thad Cochran

Chairman

The Honorable Barbara A. Mikulski

Ranking Member

Committee on Appropriations

United States Senate

The Honorable Richard Shelby

Chairman

The Honorable Sherrod Brown

Ranking Member

Committee on Banking, Housing, and Urban Affairs

United States Senate

The Honorable Orrin G. Hatch

Chairman

The Honorable Ron Wyden

Ranking Member

Committee on Finance

United States Senate

The Honorable Bob Corker

Chairman

The Honorable Ben Cardin

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
Page 48 GAO-15-561 Congo Conflict Minerals

The Honorable Jeb Hensarling

Chairman

The Honorable Maxine Waters

Ranking Member

Committee on Financial Services

House of Representatives

The Honorable Edward Royce

Chairman

The Honorable Eliot Engel

Ranking Member

Committee on Foreign Affairs

House of Representatives

The Honorable Paul Ryan

Chairman

The Honorable Sander Levin

Ranking Member

Committee on Ways and Means

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-15-561 Congo Conflict Minerals

To examine company disclosures filed with the Securities and Exchange 

Commission (SEC) for the first time in 2014 in response to the SEC 

conflict minerals disclosure rule, we downloaded the Specialized 

Disclosure reports (Form SD) and Conflict Minerals Reports from SEC’s 

publically available Electronic Data Gathering, Analysis, and Retrieval 

(EDGAR) database on July 31, 2014. We downloaded 1,324 filings 

identified as Form SDs in EDGAR.1 To review the completeness and 

accuracy of the EDGAR database, we reviewed relevant documentation, 

interviewed knowledgeable SEC and GAO officials, and reviewed prior 

GAO reports on internal controls related to SEC’s financial systems. We 

determined that the EDGAR database was sufficiently reliable for 

identifying the universe of SD filings on July 31, 2014. We reviewed the 

conflict minerals section of the Dodd-Frank Wall Street Reform and 

Consumer Protection Act2 and the requirements of the SEC conflict 

minerals disclosure rule3

We randomly sampled 147 filings from a population of 1,324 to create 

estimates generalizable to the population of all companies that filed. All 

estimates based on our sample have a margin of error of plus or minus 

10 percentages points or less at the 95 percent confidence level. 

Because we followed a probability procedure based on random 

selections, our sample is only one of a large number of samples that we 

might have drawn. Since each sample could have provided different 

estimates, we express our confidence in the precision of our particular 

to develop a questionnaire that guided our data 

collection and analysis of Form SDs and Conflict Minerals Reports. Our 

questionnaire was not a compliance review of the Form SDs and Conflict 

Minerals Reports. The questions were written in both yes/no and multiple 

choice formats. An analyst reviewed the Form SDs and Conflict Minerals 

Reports and recorded responses to the questionnaire for all of the 

companies in the sample. A second analyst also reviewed the Form SDs 

and Conflict Minerals Reports and verified the questionnaire responses 

recorded by the first analyst. Analysts met to discuss and resolve any 

discrepancies.

 1

The number of SD filings we downloaded from the public EDGAR site on July 31, 2014 

varies slightly from SEC’s reported number of 1,321 filings. Because companies can file 

amendments or request corrections to filings, any updates to SD filings made after July 

31, 2014 are not reflected in our analysis.

2

Pub. L. No. 111-203, § 1502.

3

17 C.F.R. § 240.13p-1.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 50 GAO-15-561 Congo Conflict Minerals

sample’s results as a 95 percent confidence interval. This is the interval 

that would contain the actual population value for 95 percent of the 

samples we could have drawn. We also attended an industry conference 

on conflict minerals and spoke with company representatives to obtain

additional perspectives.

To examine Department of State (State) and U.S. Agency for 

International Development (USAID) actions related to the U.S. conflict 

minerals strategy in the DRC region, we reviewed the U.S. Strategy to 

Address the Linkages between Human Rights Abuses, Armed Groups, 

Mining of Conflict Minerals and Commercial Products, developed by State 

and USAID in 2011, and State’s and USAID’s websites. We interviewed 

State and USAID officials in Washington for an update on the U.S. 

implementation of the strategy in the Democratic Republic of Congo 

(DRC) and continuing challenges. We also reviewed the Dodd-Frank Wall 

Street Reform and Consumer Protection Act.

In November 2014 we traveled to the DRC region and met with several 

State and USAID officials implementing actions related to the strategy 

and host country officials. We also met with representatives of 

nongovernmental organizations (NGO), contractors, international 

organizations, and private sector representatives to gather information 

and assess the impact of the Dodd-Frank Act and the implementation of 

the conflict minerals strategy. In addition, we visited three conflict 

minerals sites—a tantalum mine in the DRC, a tin mine in Rwanda, and a 

gold mine in Burundi—to observe operations and artisanal mining 

activities and to gain an understanding of mine certification processes 

and the challenges that mines must overcome to export minerals. We 

also reviewed documents from officials working in the region that detailed 

the various programs State and USAID are implementing.

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 eastern DRC—Rwanda, Uganda, 

and Burundi—since our June 2014 report on sexual violence in these 
Appendix I: Objectives, Scope, and 

Methodology

Page 51 GAO-15-561 Congo Conflict Minerals

areas.4 During the course of our review, we interviewed officials from 

USAID to discuss the collection of sexual violence-related data—including 

population-based surveys and case file data—in the DRC and adjoining 

countries. We contacted researchers and representatives from groups we 

interviewed from our prior review on sexual violence rates in eastern DRC 

and adjoining countries. We also traveled to New York City to meet with 

officials from the United Nations (UN) Population Fund, United Nations 

High Commissioner for Refugees, United Nations Special Representative 

of the Secretary-General on Sexual Violence in Conflict, and the United 

Nations Children’s Fund. In addition, we reviewed relevant 

documentation, such as reports and technical briefs, from various UN 

entities. To determine whether sexual violence data from the last two 

Demographic Health Survey (DHS) published reports for the DRC were 

comparable, we corresponded with and interviewed officials at ICF 

International, a firm providing technical assistance for survey design and 

implementation. Because data from the published 2008 and 2014 DHS 

for DRC were not comparable, we reported on data that ICF International 

generated at our request for the two time periods, which it determined to 

be comparable. We also conducted Internet literature searches to identify 

new academic articles containing any additional information on sexual 

violence since our 2014 report.5

We conducted this performance audit from September 2014 to August 

2015 in accordance with generally accepted government auditing 

standards. Those standards require 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 

the evidence obtained provides a reasonable basis for our findings and

conclusions based on our audit objectives.

 4

GAO, Conflict Minerals: Stakeholder Options for Responsible Sourcing Are Expanding, 

but More Information on Smelters Is Needed, GAO-14-575 (Washington, D.C.: June 26, 

2014).

5

GAO-14-575.
Appendix II: Description of Litigation

and Resulting Guidance Related to the “DRC 

Conflict Undeterminable” Classification

Page 52 GAO-15-561 Congo Conflict Minerals

In response to the appeals court’s April 2014 decision, the Securities and 

Exchange Commission (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 by either 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 as having “not been found to be ‘DRC [Democratic 

Republic of the Congo] conflict free’,” or as “DRC conflict undeterminable”

in their reports. The guidance also states that, although the rule does not 

require any company to describe its products as “DRC conflict free,” a 

company may voluntarily elect to describe any of its applicable products 

that way 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, 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 14, 2014, the appeals court denied the motion.

Appendix II: Description of Litigation

and Resulting Guidance Related to the “DRC 

Conflict Undeterminable” Classification
Appendix III: GAO Contacts and Staff 

Acknowledgments

Page 53 GAO-15-561 Congo Conflict Minerals

Kimberly M. Gianopoulos, (202) 512-8612 or gianopoulosk@gao.gov

In addition to the individual named above, Godwin Agbara (Assistant 

Director), Marc Castellano, Tina Cheng, Debbie Chung, Justin Fisher, 

Julia Jebo Grant, Emily Gupta, Stephanie Heiken, Jill Lacey, Grace Lui, 

and Andrea Riba Miller made key contributions to this report.

Appendix III: GAO Contacts and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(321043)
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