Need to Know
A company that uses any of the designated minerals is required to conduct a reasonable “country of origin” inquiry that must be performed in good faith and be reasonably designed to determine whether any of its minerals originated in the specified countries or are from scrap or recycled sources.
Companies also must exercise due diligence on the source and chain of custody of their conflict minerals, and their due diligence measures must conform to a nationally or internationally recognized due diligence framework, such as the due diligence guidance approved by the Organization for Economic Co-operation and Development (OECD).
Currently, gold is the only conflict mineral with a recognized due diligence framework for determining whether it is recycled or scrap. If a company cannot reasonably conclude after its inquiry that its gold is from recycled or scrap sources, then it is required to undertake due diligence in accordance with the OECD Due Diligence Guidance, and get an audit of its conflict minerals report.
For the other three minerals, if a company cannot reasonably conclude after its inquiry that its minerals are from recycled or scrap sources, it is required to describe the due diligence measures it exercised in its conflict minerals report.