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. Figure 1 shows the DRC’s provinces and adjoining countries. 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. 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 about 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, steel coatings on automobile parts, and some plastics. Most tantalum is used to manufacture tantalum capacitors, which enable energy storage in electronic products such as cell phones and computers, or to produce alloy additives, used in turbines in jet engines (see fig. 2). Tungsten is used in automobile manufacturing, drill bits and cutting tools, and other industrial manufacturing tools and is the primary component of filaments in light bulbs. Gold is used as reserves and in jewelry and is also used by the electronics industry, including, for example, in cell phones and laptops. 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 Canada. Gold, however, is mined in many different countries, including the DRC. Congress has focused on issues related to the DRC for more than 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. 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. The act requires SEC, State, USAID, and Commerce to take steps on matters related to the implementation of those provisions (see text box). As we have previously reported, SEC, State, USAID, and Commerce have each taken steps to address the provisions of the act. SEC adopted its conflict minerals disclosure rule in August 2012 and published the adopting release in the Federal Register in September 2012 in response to Section 1502(b) of the Dodd-Frank Act. The act required that SEC promulgate disclosure and reporting regulations regarding the use of conflict minerals from the DRC and adjoining countries (or “Covered Countries”) by April 2011. 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’ conflict minerals and to promote the exercise of due diligence on conflict mineral supply chains. 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” and “also help American consumers and investors make more informed decisions.” The rule requires companies to file a Specialized Disclosure report (Form SD) if they manufacture or contract to have manufactured products that contain conflict minerals necessary to the functionality or production of those products and, as applicable, file a CMR. The form provides general instructions to companies for filing the conflict minerals disclosure and specifies the information that their Forms SD and 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. Companies filed for the second time in response to the SEC rule in 2015 on conflict minerals used in calendar year 2014. As we previously reported, SEC adopted the final conflict minerals disclosure rule on August 22, 2012. 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 1934 and uses conflict minerals that are necessary to the functionality or production of a product manufactured or contracted by that company to be manufactured. 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 requiring a company to (1) determine whether it manufactures or contracts to have manufactured products with “necessary” conflict minerals; (2) conduct a reasonable country-of-origin inquiry (RCOI) 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. Companies that disclose that their products are DRC Conflict Free are required under the SEC rule and SEC staff guidance to include documentation of an Independent Private Sector Audit (IPSA) in their disclosure. Figure 3 depicts SEC’s flowchart summary for the conflict minerals disclosure rule. Supply chains for companies using tin, tantalum, tungsten, and gold generally begin at the mine site, where ore is extracted from the ground with mechanized or artisanal mining techniques. However, these supply chains can be complex and vary considerably, according to some industry association and company representatives. For example, in the “upstream” segment of the supply chain—that is, from mine to processing facility— ore may be purchased by a local trader and then by an exporter, who ships it to a processing facility, such as a smelter, for refinement; in other cases, the ore may be sold directly to an exporter. The “downstream” segments of conflict mineral supply chains—that is, from processing facility to manufacturer—may vary as well, depending, in part, on the type of mineral. Processing facilities are considered the “choke points” in the supply chain, since a limited number of such facilities process conflict minerals worldwide and the origin of the minerals after processing can be difficult to verify. Processing facilities primarily provide high-purity tin, tantalum, and tungsten directly to component parts manufacturers, although some sell high-purity metals through traders or exchanges. Gold refiners typically sell high-purity gold to banks or to international exchanges where gold is bought and sold, although some refiners sell gold directly to manufacturers; banks and traders may also sell gold to manufacturers, including jewelry and component parts manufacturers. Component parts manufacturers use the refined tin, tantalum, tungsten, or gold to construct individual parts—such as capacitors, engine parts, or clasps for necklaces—that they sell to equipment manufacturers. The original equipment manufacturers complete the final assembly of a product and sell the final product to the consumer. Various stakeholders—including governments, industry associations, international organizations, and international and local NGOs working in the Great Lakes Region—operate or support initiatives to promote and exercise responsible sourcing of conflict minerals. Stakeholder-developed initiatives—which include the development of guidance documents, audit protocols, and sourcing practices—put themselves out as supporting efforts by companies reporting to SEC under the rule to (1) conduct due diligence of their conflict minerals supply chain, (2) identify the source of conflict minerals within their supply chain, and (3) responsibly source conflict minerals. The initiatives can be divided into two categories: global or in-region. Most responsible sourcing initiatives follow the Organisation for Economic Co-operation and Development’s (OECD) due diligence guidance. The guidance is for use by any company potentially sourcing minerals or metals from conflict-affected and high-risk areas and, according to the OECD, is one of the only international frameworks available to help companies meet their due diligence reporting requirements. Global sourcing initiatives, such as the Conflict-Free Smelter Program, the Responsible Gold Program, and the Chain-of-Custody Certification Program, may minimize the risk that minerals that have been exploited by illegal armed groups will enter the supply chain and may also support companies’ efforts to identify the source of the conflict minerals across the supply chain around the world. In-region sourcing initiatives, such as the Conflict-Free Tin Initiative (CFTI), the International Conference on the Great Lakes Region (ICGLR) regional certification mechanism, and the ITRI Tin Supply Chain Initiative (iTSCi), may support responsible sourcing of conflict minerals from Central Africa and the identification of specific mines of origin for those minerals.