On August 22, 2012, the SEC adopted final rules to implement the conflict minerals provisions in Section 1502 of the Dodd-Frank Act, which require companies to make disclosures concerning their use of conflict minerals originating in the Democratic Republic of the Congo and adjoining countries. Although the first disclosures are not due until May 31, 2014, companies should begin to analyze whether they are subject to the rules and determine the procedures necessary to perform the required supply chain due diligence.

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