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Does the company that you are evaluating include any language in its conflict minerals report that indicates that it has purposefully avoided sourcing from conflict-affected and high risk areas and/or countries covered by the US law?
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Section 1502 is a disclosure requirement that calls on companies to determine whether their products contain certain minerals – by carrying out supply chain due diligence – and to report this to the Securities and Exchange Commission (SEC). As such, Section 1502 does not require companies to stop sourcing from the Democratic Republic of Congo or neighbouring countries that are covered by the law. However, some companies have reported in their conflict minerals reports that they have chosen to avoid or stop sourcing from countries that are covered by the law, rather than remain responsibly engaged.


Once you have identified your company's conflict minerals report it's time to read through it! To establish whether the company you are evaluating has chosen to avoid or withdraw from the countries covered by Section 1502 of the Dodd Frank Act (as a reminder, these are: Democratic Republic of the Congo (DRC), Central Africa Republic, South Sudan, Zambia, Angola, The Republic of the Congo,Tanzania, Burundi, Rwanda, Uganda) you need to read through the report narrative. Watch out for phrases like 'we no longer source from' or 'we avoid buying or sourcing from'.