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entitled 'Conflict Minerals: Stakeholder Options for Responsible 
Sourcing Are Expanding, but More Information on Smelters Is Needed' 
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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

June 2014: 

Conflict Minerals: 

Stakeholder Options for Responsible Sourcing Are Expanding, but More 
Information on Smelters Is Needed: 

GAO-14-575: 

GAO Highlights: 

Highlights of GAO-14-575, a report to congressional committees. 

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 
reports from the United Nations. Congress included a provision in the 
2010 Dodd-Frank Wall Street Reform and Consumer Protection Act to 
address the trade in “conflict minerals”—tin, tantalum, tungsten, and 
gold. Section 1502 of the Act directed several U.S. agencies to report 
or focus on issues related to conflict minerals. 

This report examines, among other things, (1) the extent to which 
relevant U.S. agencies have undertaken activities related to 
responsible sourcing of conflict minerals and (2) what is known about 
the status of, and information provided by, stakeholder initiatives 
focused on responsible sourcing of conflict minerals from the DRC and 
adjoining countries. GAO reviewed and analyzed documents and data 
covering 2003 through 2014. We interviewed representatives from State, 
USAID, SEC, Commerce, nongovernmental organizations, industry, and 
international organizations who are cognizant of conflict minerals 
issues. 

What GAO Found: 

Since the Dodd-Frank Wall Street Reform and Consumer Protection Act 
(the Act) was passed in 2010, relevant U.S. agencies have undertaken 
various activities related to responsible sourcing of conflict 
minerals from the Democratic Republic of the Congo (DRC) and adjoining 
countries. In response to the Act, the Department of State (State) and 
the U.S. Agency for International Development (USAID) developed a 
strategy in 2011 to address the linkages among human rights abuses, 
armed groups, and the mining of conflict minerals and are implementing 
various strategy objectives. The Securities and Exchange Commission 
(SEC) issued a rule in 2012 requiring certain companies to disclose 
the source and chain of custody of necessary conflict minerals in 
their products. However, the Department of Commerce (Commerce) has not 
yet compiled a list of all conflict minerals processing facilities—-
smelters and refiners—-known worldwide, required by January 2013 by 
the Act. Commerce cited difficulties with, for example, tracking 
conflict minerals operations but told GAO that it had completed 
outreach efforts with the majority of stakeholders. Commerce did not 
have a plan of action, with associated time frames, for developing and 
reporting on the list of conflict minerals processing facilities 
worldwide. Standard practices in program and project management 
include, among other things, developing a plan to execute specific 
projects needed to obtain defined results within a specific time 
frame. An action plan with timeframes could better position Commerce 
to report on the status of its efforts to produce a final list to 
Congress and to hold its personnel accountable for completing 
activities. 

Over the past several years, a number of stakeholders—foreign 
governments, multilateral organizations, and industry associations, 
among others—have expanded, or made plans to expand, initiatives 
focused on responsible sourcing of conflict minerals in the DRC and 
adjoining countries. These stakeholder initiatives, such as in-region 
tracing of conflict minerals and development of guidance documents and 
audit protocols, have grown to include new mine sites, countries, and 
smelters. For example, the Conflict-Free Smelter Program, an industry-
led effort, has expanded from 26 smelters certified as conflict-free 
in 2013 to 85 smelters as of April 25, 2014 (see table). New 
stakeholder initiatives are also underway or planned in the region, 
including the first responsible sourcing initiative in the Congo-
Brazzaville. Some initiatives have yielded publicly available 
information, including data on production of conflict-free minerals 
and export data. For example, one stakeholder has reported production 
data for tin, tungsten, and tantalum from three provinces in the DRC 
and in Rwanda. 

Table: Number of Smelters and Refiners in the Conflict-Free Smelter 
Program as of April 25, 2014: 

Mineral: Tantalum; 
Number of smelters/refiners certified as compliant: 28; 
Number of smelters/refiners working toward certification: 1; 
Total: 29. 

Mineral: Tin; 
Number of smelters/refiners certified as compliant: 13; 
Number of smelters/refiners working toward certification: 14; 
Total: 27. 

Mineral: Tungsten; 
Number of smelters/refiners certified as compliant: 1; 
Number of smelters/refiners working toward certification: 8; 
Total: 9. 

Mineral: Gold; 
Number of smelters/refiners certified as compliant: 43; 
Number of smelters/refiners working toward certification: 2; 
Total: 45. 

Mineral: Total; 
Number of smelters/refiners certified as compliant: 85; 
Number of smelters/refiners working toward certification: 25; 
Total: 110. 

Source: Conflict-Free Sourcing Initiative data, GAO (analysis). 

[End of table] 

What GAO Recommends: 

GAO recommends that the Secretary of Commerce provide Congress a plan 
that outlines the steps, with associated timeframes, to develop and 
report the required information about smelters and refiners of 
conflict minerals worldwide. Commerce concurred with GAO’s 
recommendation and noted that it will submit a listing of all known 
conflict minerals processing facilities worldwide to Congress by 
September 1, 2014. 

View [hyperlink, http://www.gao.gov/products/GAO-14-575]. For more 
information, contact Kimberly M. Gianopoulos at (202) 512-8612 or 
gianopoulosk@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

U.S. Agencies Have Taken Actions Related to Responsible Sourcing of 
Conflict Minerals, but Commerce Has Not Yet Fulfilled Its Requirements: 

Stakeholder Initiatives Are Expanding and Provide Some Information on 
Sourcing of Conflict Minerals: 

Little Additional Information on Rate of Sexual Violence in Eastern 
DRC and Adjoining Countries since July 2013: 

Conclusions: 

Recommendation for Executive Action: 

Agency and Third Party Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: State Department Map of Armed Groups Present at Mine 
Sites in the Democratic Republic of the Congo: 

Appendix III: SEC Flowchart Summary of the Disclosure Process for the 
Final Conflict Minerals Rule: 

Appendix IV: Sample Data from the ITRI Supply Chain Initiative: 

Appendix V: Conflict Mineral Production and Export Data as Reported by 
the DRC and Rwandan Governments: 

Appendix VI: Conflict Minerals Data from the International Trade 
Centre Data on Global Conflict Mineral Imports: 

Appendix VII: Comments from the Department of Commerce: 

Appendix VIII: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Number of Smelters and Refiners in the Conflict-Free Smelter 
Program as of April 25, 2014: 

Table 2: Production of Minerals from Maniema Covered by iTSCi for Q1 
and Q2 of 2013, in Metric Tons: 

Table 3: Sales of Minerals from Maniema Covered by iTSCi for Q1 and Q2 
of 2013, in Thousands of U.S. Dollars: 

Table 4: Production of Minerals from South Kivu Covered by iTSCi for 
Q4 of 2012 through Q2 of 2013, in Metric Tons: 

Table 5: Sales of Minerals from South Kivu Covered by iTSCi for Q4 of 
2012 through Q2 of 2013, in Thousands of U.S. Dollars: 

Table 6: Production of Minerals from Katanga Covered by iTSCi for Q2 
of 2011 through Q2 of 2013, in Metric Tons: 

Table 7: Sales of Minerals from Katanga Covered by iTSCi for Q2 of 
2011 through Q2 of 2013, in Thousands of U.S. Dollars: 

Table 8: Production of Minerals from Rwanda Covered by iTSCi for Q2 of 
2011 through Q2 of 2013, in Metric Tons: 

Table 9: Sales of Minerals from Rwanda Covered by iTSCi for Q2 of 2011 
through Q2 of 2013, in Thousands of U.S. Dollars: 

Table 10: Total Volume of Tin Production and Export from DRC for 2003-
2012, in Metric Tons: 

Table 11: Total Volume of Tantalum Production and Export from DRC for 
2003-2012, in Metric Tons: 

Table 12: Total Volume of Tungsten Production and Export from DRC for 
2003-2012, in Metric Tons: 

Table 13: Total Volume of Gold Production and Export from DRC for 2003-
2012, in Metric Tons: 

Table 14: Total Volume of Tin, Tantalum, and Tungsten Exports from 
Rwanda January-August 2013, in Metric Tons: 

Table 15: Total Value of Tin, Tantalum, and Tungsten Exports from 
Rwanda January-August 2013, in Thousands of U.S. Dollars: 

Table 16: ITC Estimates of Exports of Conflict Minerals from the 
Democratic Republic of the Congo for Fiscal Years 2009-2013, in Metric 
Tons: 

Table 17: ITC Estimates of Export Value of Conflict Minerals from the 
DRC for F Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

Table 18: ITC Estimates of Exports of Conflict Minerals from Angola 
for Fiscal Years 2009-2012, in Metric Tons: 

Table 19: ITC Estimates of Export Value of Conflict Minerals from 
Angola for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

Table 20: ITC Estimates of Exports of Conflict Minerals from Burundi 
for Fiscal Years 2009-2012, in Metric Tons: 

Table 21: ITC Estimates of Export Value of Conflict Minerals from 
Burundi for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

Table 22: ITC Estimates of Exports of Conflict Minerals from Central 
African Republic for Fiscal Years 2009-2012, in Metric Tons: 

Table 23: ITC Estimates of Export Value of Conflict Minerals from 
Central African Republic for Fiscal Years 2009-2013, in Thousands of 
U.S. Dollars: 

Table 24: ITC Estimates of Exports of Conflict Minerals from Rwanda 
for Fiscal Years 2009-2012, in Metric Tons: 

Table 25: ITC Estimates of Export Value of Conflict Minerals from 
Rwanda for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

Table 26: ITC Estimates of Export of Conflict Minerals from Tanzania 
for Fiscal Years 2009-2012, in Metric Tons: 

Table 27: ITC Estimates of Export Value of Conflict Minerals from 
Tanzania for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

Table 28: ITC Estimates of Exports of Conflict Minerals from Uganda 
for Fiscal Years 2009-2012, in Metric Tons: 

Table 29: ITC Estimates of Export Value of Conflict Minerals from 
Uganda for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

Table 30: ITC Estimates of Exports of Conflict Minerals from Zambia 
for Fiscal Years 2009-2012, in Metric Tons: 

Table 31: ITC Estimates of Export Value of Conflict Minerals from 
Zambia for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

Figures: 

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

Figure 2: Simplified Conflict Minerals Supply Chain: 

Figure 3: Timeline of the Starting Dates of Stakeholder-led 
Initiatives from 2008 to June 2014: 

Figure 4: Timeline of Population-Based Surveys Estimating the Rate of 
Sexual Violence in Eastern DRC, Rwanda, Uganda, and Burundi: 

Figure 5: State Department Map of the Presence of Armed Groups at Mine 
Sites in the Democratic Republic of the Congo, as of February 2014: 

Figure 6: SEC Flowchart Summary of Conflict Minerals Rule: 

Abbreviations: 

BGR: German Federal Institute for Geosciences and Natural Resources: 

CFSI: Conflict-Free Sourcing Initiative: 

CFTI: Conflict-Free Tin Initiative: 

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: 

EICC: Electronic Industry Citizenship Coalition: 

GeSI: Global e-Sustainability Initiative: 

EU: European Union: 

ICGLR: International Conference on the Great Lakes Region: 

iTSCi: ITRI Tin Supply Chain Initiative: 

LBMA: London Bullion Market Association: 

M-23: March 23 Movement: 

MONUSCO: UN Organization Stabilization Mission in the Democratic 
Republic of the Congo: 

NGO: nongovernmental organization: 

OECD: Organisation for Economic Co-operation and Development: 

PPA: Public-Private Alliance for Responsible Minerals Trade: 

SEC: Securities and Exchange Commission: 

State: United States Department of State: 

UN: United Nations: 

USAID: United States Agency for International Development: 

[End of section] 

United States Government Accountability Office: 
GAO:
441 G St. N.W. 
Washington, DC 20548: 

June 26, 2014: 

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. The International Rescue Committee has previously estimated 
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.[Footnote 1] Despite some success in efforts to 
improve security in eastern DRC--notably, the November 2013 defeat of 
M-23, an illegal armed group,[Footnote 2] as well as campaigns against 
other illegal armed groups--the UN reported that as of December 2013, 
illegal armed groups in eastern DRC continued to pose a threat to 
security, to be responsible for human rights abuses and displacements 
of people, and to derive funding from the illicit production, trade, 
and smuggling of conflict minerals.[Footnote 3] 

Citing the continuing urgency of the humanitarian situation and the 
need to take action, in July 2010, Congress included in the Dodd-Frank 
Wall Street Reform and Consumer Protection Act (hereafter referred to 
as the Act or Dodd-Frank Act) provisions pertaining to trade involving 
conflict minerals--tantalum, tin, tungsten, and gold.[Footnote 4] 
Section 1502 of the Act directed 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, including provisions related to 
responsible sourcing of conflict minerals from the DRC and the 
adjoining countries.[Footnote 5] The Act specifically directed the SEC 
to promulgate a rule, which SEC issued in August 2012, that requires 
certain issuers to disclose annually to SEC whether any of such 
minerals are necessary to the functionality or production of products 
manufactured, or contracted to be manufactured, by the issuer 
originated in the DRC or adjoining country and if so, to provide an 
additional report.[Footnote 6] The Act also 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 annually, beginning in 2011, on the rate of sexual 
violence in war-torn areas of DRC and adjoining countries, among other 
things. 

To address our mandates, since July 2011 we have issued several 
reports on topics ranging from the rate of sexual violence in the DRC 
and adjoining countries to SEC's rule and initiatives focused on 
responsible sourcing of minerals.[Footnote 7] Because the first SEC-
required disclosures of manufacturers' use of conflict minerals were 
not due to SEC until June 2014, and because sufficient time must 
elapse to allow the rule's full impact to materialize, we have not yet 
addressed the effectiveness of SEC's conflict minerals rule as 
required under the legislation. Moreover, our ability to report on the 
rule's effectiveness will depend on the availability of information on 
stakeholder initiatives to, for example, monitor, ensure, or report on 
responsible sourcing of conflict minerals from the DRC and adjoining 
countries.[Footnote 8] Consequently, in this report, we examine: 

1. the extent to which relevant U.S. agencies have taken actions 
related to the responsible sourcing of conflict minerals; 

2. what is known about the status of, and any information provided by, 
stakeholder initiatives focused on responsible sourcing of conflict 
minerals from the DRC and adjoining countries; and: 

3. any new information about the rate of sexual violence in eastern 
DRC and three adjoining countries--Burundi, Rwanda, and Uganda--that 
has become available since we issued our 2013 report.[Footnote 9] 

To address our first and second objectives, we reviewed and analyzed 
available data covering 2003 through 2014 on conflict minerals from 
the DRC and adjoining countries and from responsible sourcing 
initiatives, as well as reports and other documents from relevant U.S. 
agencies, foreign governments, multilateral organizations, 
nongovernmental organizations (NGOs), and industry associations. 
Because the data were not used to support findings, conclusions, or 
recommendations, we did not assess their reliability. We also 
interviewed State, USAID, Commerce, and SEC officials as well as 
stakeholder representatives from international organizations, NGOs, 
and industry associations who are cognizant of conflict minerals 
issues. We selected these stakeholders based on their expertise on 
responsible sourcing issues, because they represented a range of 
perspectives on conflict minerals, and because we had established 
contacts with these entities on our last review.[Footnote 10] In 
addition, some of the stakeholders we talked to have been working on 
the ground in the DRC. The stakeholders we spoke with constitute a 
nongeneralizable sample, and the information we gathered from them 
cannot be used to infer views of other stakeholders cognizant of 
conflict minerals issues. To address our third objective, we reviewed 
and analyzed relevant documents and interviewed representatives from 
State, USAID, various UN agencies, relevant NGOs, and researchers to 
identify any new data on sexual violence. Specifically, we followed up 
with officials from those groups we interviewed for our prior review 
on sexual violence rates in eastern DRC and adjoining 
countries.[Footnote 11] We also conducted Internet literature searches 
to identify new academic articles containing any additional 
information available since our 2013 report. See appendix I for a 
complete description of our scope and methodology. 

We conducted this performance audit from September 2013 to June 2014 
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. 

Background: 

Brief History of Conflict in the DRC and the Region: 

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. 

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

[Refer to PDF for image: map] 

Source: GAO based on UN map. GAO-14-575. 

[End of figure] 

Since its independence in 1960, the DRC has undergone political 
upheaval, including a civil war, according to State. In particular, 
the eastern DRC has continued to be plagued by violence often 
perpetrated by illegal armed groups and some members of the Congolese 
national military against civilians. 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, that were perpetrated by 
armed groups and some members of the Congolese national military. 
[Footnote 12] Although M-23 eventually withdrew from the cities, the 
group's presence in the region continued. In December 2012, the 
Ugandan president began to broker peace talks, known as the Kampala 
Dialogue, between M-23 and the DRC government, aimed at reaching a 
final and principled agreement that ensured the disarmament and 
demobilization of M-23 and accountability for human rights abuses. The 
M-23 was defeated in November 2013 by the Congolese national military 
with support from UN forces. In December 2013, the former M-23 and the 
DRC each signed individual declarations that, among other things, set 
out the conditions for the disarmament, demobilization, and 
reintegration of M23 into Congolese society and called for those 
responsible for war crimes and crimes against humanity to be held 
accountable. 

Prior to the defeat of M-23, in February 2013, the 11 countries in the 
region adopted the "Peace, Security and Cooperation Framework for the 
Democratic Republic of the Congo and the Region."[Footnote 13] Some of 
the adjoining countries in the region have also experienced recent 
turmoil, which has led to flows of large numbers of refugees into the 
DRC in addition to internally displaced persons.[Footnote 14] The 
United Nations High Commissioner for Refugees (UNHCR) estimated, as of 
mid 2013, that there were close to 50,000 refugees from the Central 
African Republic, in addition to over 120,000 refugees from other 
countries, as well as around 2.6 million internally displaced persons 
living in camps or with host families in the DRC. 

U.S. Government Response to Conflict in 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,[Footnote 15] stating 
that U.S policy is to engage with governments working for peace and 
security throughout the DRC and hold accountable individuals, 
entities, and countries working to destabilize the government. In July 
2010, Congress passed the Dodd-Frank Act, which included several 
provisions in section 1502 of the Act concerning conflict minerals in 
the DRC and adjoining countries. The Act directs State, USAID, SEC, 
and Commerce to take steps on matters related to the implementation of 
those provisions (see text box). 

Text box: 

Provisions in the Dodd-Frank Act Related to Conflict Minerals in the 
DRC 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 SEC, in consultation with State, to 
promulgate disclosure and reporting regulations regarding the use of 
conflict minerals from DRC and adjoining countries; 
* Section 1502(c) requires State and 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 Commerce report, among other things, a 
listing of all known conflict minerals processing facilities worldwide. 

Source: GAO analysis. GAO-14-575. 

[End of text box] 

In addition, in July 2013, the United States appointed the current 
Special Envoy for the Great Lakes Region and the DRC, whose office 
develops and leads the implementation of U.S. regional policy on cross-
border security, political, economic and social issues. The Special 
Envoy leads U.S. efforts to support the implementation of the Peace, 
Security, and Cooperation Framework Agreement, including the 
development and implementation of a comprehensive strategy to stop 
human suffering and violence in the region, by promoting political, 
economic, and social reconciliation. 

International Response to Conflict in the DRC: 

In 1999, the UN Security Council authorized peacekeeping operations in 
the DRC, known as the UN Organization Mission in Democratic Republic 
of the Congo (MONUC).[Footnote 16] MONUC's mission included achieving 
a ceasefire and protecting civilians and other nonmilitary personnel 
from threats of physical violence. In 2010, MONUC was replaced by the 
UN Organization Stabilization Mission in the Democratic Republic of 
the Congo (MONUSCO), whose priorities also include protecting 
civilians and stabilizing the country. 

The international community has also responded to the conflict in the 
DRC and adjoining countries by appointing special envoys to the 
region. For example, in March 2013, the UN appointed a Special Envoy 
of the Secretary-General for the Great Lakes Region to support the 
implementation of the 11-nation Peace, Security and Cooperation 
Framework for the Democratic Republic of the Congo and the Region. 
[Footnote 17] In June 2013, the UN also appointed the current Special 
Representative of the Secretary-General for the Democratic Republic of 
the Congo and Head of MONUSCO. Both the European Union and African 
Union also have appointed representatives for the Great Lakes Region. 
To address imminent threats to peace and security, the UN Security 
Council also authorized the deployment of a force intervention brigade 
within the current peacekeeping operations in the DRC on March 28, 
2013. The objectives of the new force based in North Kivu province are 
to neutralize armed groups, reduce the threat they pose to state 
authority and civilian security, and make space for stabilization 
activities.[Footnote 18] 

In addition, the European Union (EU) is exploring possible legislation 
related to conflict minerals and responsible sourcing.[Footnote 19] 
According to a European Commission release, in March 2014, the EU 
proposed a draft regulation setting up an EU system of self-
certification for importers of tin, tantalum, tungsten, and gold for 
imports into the EU. The draft regulation indicated that the self-
certification would align with the Organization for Economic 
Cooperation and Development's (OECD) "OECD Due Diligence Guidance for 
Responsible Supply Chains of Minerals from Conflict-Affected and High-
Risk Areas," which includes a five-step framework for risk-based due 
diligence in the supply chain.[Footnote 20] According to the release, 
the regulation gives EU importers an opportunity to deepen ongoing 
efforts to ensure clean supply chains when trading legitimately with 
operators in conflict-affected countries. 

Conflict Minerals Supply Chains: 

Side bar: 

Uses of Conflict Minerals: 
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 as well as used 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 also used by the 
electronics industry.
Source: GAO-12-763. GAO-14-575. 

[End of side bar] 

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.[Footnote 21] 
However, these supply chains can be complex and vary considerably, 
according to some industry association and company representatives. 
For example, as figure 2 shows, in the "upstream" segment of the 
supply chain--that is, from mine to smelter--ore may be purchased by a 
local processor or trader and then by an exporter, who ships it to 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 smelter to manufacturer--may vary as well, 
depending in part on the type of mineral. Figure 2 provides a 
simplified depiction of the supply chain for the four conflict 
minerals. 

Figure 2: Simplified Conflict Minerals Supply Chain: 

[Refer to PDF for image: illustration] 

Mine: Metal ores to: Local processors/traders: or Exporter; 
Local processors/traders: Metal ores to: Exporter; 
Exporter: Metal ores to Smelters; 
Smelters: Metal ores, Metals and products to: Banks and exchanges; 
Banks and exchanges: Metals and products to: Component parts 
manufacturers; 
Component parts manufacturers: Metals and products to: Original 
equipment manufacturers. 

Source: GAO analysis. GAO-14-575. 

[End of figure] 

Smelters and refiners are considered the "choke points" in the supply 
chain, since a limited number of smelters and refiners process 
conflict minerals worldwide and the origin of the minerals after 
processing can be difficult to verify. Smelters 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 
for use as a store of value or to international exchanges where gold 
is bought and sold,[Footnote 22] 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 original equipment 
manufacturers. The original equipment manufacturers complete the final 
assembly of a product and sell the final product to the consumer. 

Responsible Sourcing Initiatives: 

Side bar: 

Global and In-Region Sourcing Initiatives: 
Global sourcing initiatives 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 may support responsible sourcing of 
conflict minerals from Central Africa and the identification of 
specific mines of origin for those minerals. Such initiatives in DRC 
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-14-575. 

[End of side bar] 

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--support 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.[Footnote 23] 

Most responsible sourcing initiatives follow OECD's due-diligence 
guidance.[Footnote 24] The guidance is for use by any company 
potentially sourcing minerals or metals from conflict-affected and 
high-risk areas and, according to OECD, is one of the only 
international frameworks available to help companies meet their due 
diligence reporting requirements. 

U.S. Agencies Have Taken Actions Related to Responsible Sourcing of 
Conflict Minerals, but Commerce Has Not Yet Fulfilled Its Requirements: 

Since the Act was passed in 2010, State, USAID, SEC, and Commerce have 
undertaken activities related to implementation of the Act's conflict 
minerals provisions, including activities related to responsible 
sourcing of such minerals from the DRC and adjoining countries. As 
required by the Act, State and USAID developed a strategy in 2011 
aimed at addressing the linkages between human rights abuses, armed 
groups, the mining of conflict minerals, and commercial products and 
are implementing various objectives of the strategy. State also 
produced a map of mineral-rich areas under control of armed groups in 
the DRC. SEC issued its required conflict minerals rule in 2012. As of 
May 2014, Commerce had taken steps toward producing a list of all 
conflict minerals processing facilities worldwide, which the Act 
required by January 2013, but had not completed the task. Moreover, 
Commerce had not developed a plan of action with associated timeframes 
for how and when it expects to complete this effort and report to 
Congress. Standard practices in program and project management and 
execution include, among other things, developing a plan to execute 
specific projects needed to obtain defined results within a specific 
time frame.[Footnote 25] State, USAID, SEC, and Commerce also have 
engaged in activities involving stakeholder partnerships and outreach 
and have provided technical assistance to other governments related to 
activities focused on the responsible sourcing of conflict minerals. 

State, USAID, and SEC Have Addressed the Act's Requirements, and 
Commerce Is Working toward Fulfilling Its Requirements: 

The Act directed State, USAID, SEC, and Commerce to undertake various 
activities to implement its provisions related to conflict minerals. 
Since the Act was passed in 2010, the agencies have taken the 
following actions. 

State and USAID Developed a Strategy, and State Produced a Conflict 
Minerals Map: 

Responding to the Act, State and USAID developed a strategy in 2011 to 
address the linkages among human rights abuses, armed groups, the 
mining of conflict minerals, and commercial products. The Act required 
State and USAID to submit, by January 2011,[Footnote 26] a strategy to 
address the linkages between human rights abuses, armed groups, mining 
of conflict minerals, and commercial products. The strategy document 
that State and USAID submitted to Congress in 2011 lists five 
objectives: (1) promote an appropriate role of security forces, (2) 
enhance civilian regulation of minerals trade in the DRC, (3) protect 
artisanal miners and local communities, (4) strengthen regional and 
international efforts, and (5) promote due diligence and responsible 
trade through public outreach. The strategy includes activities 
corresponding with each of these objectives--for example, building the 
capacity of civilian mining authorities in the DRC to certify mine 
sites, supporting the implementation and coordination of certification 
and traceability schemes, building the capacity of the ICGLR related 
to mineral audit mechanisms, and engaging with industries and civil 
society groups regarding supply chain due diligence efforts. State and 
USAID officials indicated that they have been implementing objectives 
of the strategy over the past few years. According to the U.S. Special 
Envoy for the Great Lakes Region and the DRC, the strategy remains 
relevant and accurate and State has used it in conjunction with other 
U.S. government agencies as a roadmap for efforts to help break the 
link between armed groups and conflict minerals. 

In addition, in 2011, State developed a map of mineral-rich zones and 
areas under control of armed groups in the DRC and has subsequently 
published several updated maps, as required by the Act.[Footnote 27] 
The maps are focused on the exploitation of tin, tantalum, tungsten, 
and gold in the provinces of North and South Kivu and parts of 
Orientale, Maniema, and Katanga provinces. According to State, the 
most current map, which State published in February 2014, was based on 
data from surveys conducted in 2013 by the International Peace 
Information Service (IPIS)--an NGO--and on information from 
consultations with the DRC government, the UN Group of Experts, and 
MONUSCO (see appendix II for the 2014 map).[Footnote 28] State 
reported that lack of complete or fully verifiable data makes it 
difficult to confirm the location of many mine sites, to establish 
which mine sites are active at any given time, and to comprehensively 
verify reports of armed groups or other entities that are either 
present at mines or have access to revenue streams emanating from 
them. State officials indicated that in the future the map may become 
digital rather than paper based. 

SEC Issued Its Conflict Minerals Rule in 2012: 

As we previously reported,[Footnote 29] SEC issued its conflict 
minerals rule in August 2012.[Footnote 30] The Act required that SEC 
promulgate, by April 2011, disclosure and reporting regulations 
regarding the use of conflict minerals from the DRC and adjoining 
countries.[Footnote 31] 

SEC issued a "frequently asked questions" (FAQ) document in May 2013 
to address questions by companies that will have to report to SEC 
under the conflict minerals rule. SEC officials indicated that these 
FAQs included questions posed most often by companies regarding 
interpretation of the rule. In April 2014, SEC issued additional FAQs 
addressing questions that mostly pertained to the independent private 
sector audit of companies' conflict minerals disclosure reports. 
According to an SEC official, these FAQs were based on interpretive 
questions asked by SEC-reporting companies and the audit community. 

In January 2014, SEC made "Form SD," a specialized disclosure form for 
reporting compliance with the conflict minerals rule, available for 
electronic filing. The form, originally published with the conflict 
minerals rule, provides general instructions to SEC-reporting 
companies for filing the conflict minerals disclosure and specifies 
the information that their conflict minerals reports must include. SEC-
reporting companies were required to file under the rule for the first 
time by June 2, 2014, and annually thereafter on May 31.[Footnote 32] 
According to SEC officials, based on preliminary feedback they 
received, they anticipated that most SEC-reporting companies subject 
to the rule would be unable to determine whether or not their products 
qualified as "DRC conflict-free."[Footnote 33] 

Commerce Has Taken Steps but Has Not Provided a List of Conflict 
Minerals Processing Facilities to Congress: 

More than a year after the deadline required by the Act, Commerce has 
not yet fulfilled its mandate under section 1502 of the Act. Section 
1502 directed Commerce to report, among other things, a list of all 
known conflict minerals processing facilities worldwide to appropriate 
congressional committees annually starting no later than 30 months 
after the Act's enactment--that is, by January 2013.[Footnote 34] As 
of May 2014, Commerce had not developed such a list or developed a 
plan of action, with associated time frames, for completing this 
requirement and reporting it to Congress. Standard practices in 
program and project management include developing, among other things, 
a program plan to execute specific projects needed to obtain defined 
programmatic results within a specific time frame. In January 2014, 
Commerce officials told us that they had identified entities that they 
hoped would help them identify publicly available information about 
conflict minerals and identify stakeholders who are knowledgeable 
about conflict minerals issues. Specifically, Commerce officials 
indicated that they had assembled a proposed and internal outreach 
plan, which includes meeting with stakeholders to discuss how these 
organizations have gathered information on conflict mineral smelters 
and identifies other efforts that Commerce can explore to develop the 
list of conflict minerals processing facilities. Commerce officials 
also indicated that they anticipated a 3-to 4-month time frame for the 
proposed outreach efforts to talk to stakeholders. In May 2014, 
Commerce officials stated that they had completed discussions with the 
majority of the stakeholders identified in the outreach plan and have 
developed several preliminary lists of conflict minerals processing 
facilities, based on information they obtained from the stakeholders. 
However, Commerce officials stated that they did not have a timeframe 
for completing the final list for Congress. 

Commerce officials said that they had encountered some challenges 
associated with gathering data on conflict minerals to help inform 
their outreach plan and required reporting. For example, according to 
the officials, conflict minerals and mining operations are difficult 
to track; because the equipment used to process conflict minerals can 
be moved easily, such operations can emerge in different locations. In 
addition, Commerce officials mentioned that some conflict minerals 
data may be inaccessible to the U.S. government because a large number 
of conflict mineral smelters are in China.[Footnote 35] Having an 
action plan with associated timeframes could better position Commerce 
to report on the status of its efforts to compile a list of conflict 
minerals processing facilities worldwide and to hold its personnel 
accountable for completing its related activities. 

Some stakeholders that we contacted, including government and industry 
officials and representatives of the UN Group of Experts and an NGO, 
indicated that a comprehensive list of conflict minerals smelters and 
refiners--considered the "choke point" of the supply chain--would be 
very useful in the effort to ensure responsible sourcing of minerals 
in the DRC and adjoining countries. According to these stakeholders, 
such a list would enable companies that are subject to the SEC rule to 
maintain transparency regarding their supply chains, particularly in 
their communications with smelters, and would also provide companies 
the information they need for their SEC-required conflict minerals 
disclosure reports. 

U.S. Agencies Have Engaged in Partnerships and Outreach and Provided 
Technical Assistance to Stakeholders: 

U.S. government agencies have engaged in a variety of activities that 
involve partnerships and coordination with other stakeholders or 
outreach to stakeholders, and some agencies have provided technical 
assistance to stakeholders regarding responsible sourcing of conflict 
minerals. Some agencies' activities contribute to global and in-region 
responsible sourcing initiatives and some of the activities address 
the implementation of objectives outlined in the strategy to address 
the linkages between human rights abuses, armed groups, and the mining 
of conflict minerals. 

U.S. Agency Partnerships and Coordination Efforts: 

Some U.S. agencies have partnered and coordinated with other 
stakeholders--other government agencies, industry, and civil society--
regarding issues related to responsible sourcing of conflict minerals. 
For example: 

* State and USAID, both in headquarters and posts or missions 
overseas, and other U.S. agencies coordinate with one another on 
weekly or biweekly conference calls to discuss the progress of 
responsible sourcing efforts, provide updates on recent events, and 
collaborate on future events, according to State and USAID officials. 

* USAID works in a collaborative and coordinated manner with State in 
Washington and regionally, using the 2011 U.S. strategy as a framework 
for the coordination, according to USAID officials. The officials 
indicated that funding also has been coordinated between the two 
agencies across the five objectives of the strategy and totals over 
$25 million, as of 2013. 

* State and USAID coordinate with other stakeholders through the 
Public-Private Alliance for Responsible Minerals Trade (PPA) to fund 
and support organizations working on responsible sourcing efforts. 
Both State and USAID are on the PPA's Governance Committee, which 
consists of participants from foreign governments, industry, and civil 
society.[Footnote 36] 

* USAID has partnered with the International Organization for 
Migration to help enhance civilian control of the DRC's mineral trade 
through infrastructure improvements and institutional reforms, 
according to agency officials. The officials reported that with USAID 
funding, the organization will also establish pilot certification and 
traceability systems in and around the mineral trading centers and 
other areas of South and North Kivu.[Footnote 37] 

* USAID has partnered and coordinated with stakeholders in the DRC, 
according to agency officials. For example, the officials said that 
USAID is coordinating with the DRC government regarding various 
aspects of minerals trade, is involved in the multi-stakeholder Mining 
Thematic Group in the DRC, and facilitates the Eastern Congo Mining 
Coordination Team. 

* On a multilateral level, both USAID and State participate in the 
OECD Responsible Sourcing Stakeholder Forums held every 6 months, 
according to USAID officials. This forum, coordinated by the ICGLR, 
OECD, and the UN Group of Experts, is a platform for governments, the 
private sector, international organizations, and civil society to 
share experiences with implementation of supply chain due diligence 
for responsible sourcing of minerals from conflict-affected and high-
risk areas. Both State and USAID officials have participated at times 
as facilitators of these forums. 

* The current U.S. Special Envoy for the Great Lakes Region and the 
DRC has collaborated with other stakeholders, such as the UN Special 
Envoy for the Great Lakes, the African Union, and other multilateral 
and bilateral partners, to strengthen international coordination 
mechanisms on the crisis in the Great Lakes, according to State. These 
efforts have taken place under the Peace, Security, and Cooperation 
Framework Agreement for the DRC and the Region. 

U.S. Agency Outreach Efforts: 

A couple of U.S. government agencies indicated that they have 
conducted outreach to various stakeholders to promote responsible 
sourcing of conflict minerals and to obtain information about conflict 
mineral sourcing and supply chains. For example, State and Commerce 
officials reported the following. 

* State officials told us that State has engaged with foreign 
governments and industry associations regarding the Dodd-Frank Act 
requirements. According to these officials, State's efforts have 
included sending letters about section 1502 of the Act to foreign 
governments that are prominent in the conflict mineral supply chain as 
well as encouraging these governments and companies in those countries 
to support the aim of the legislation. In a November 2013 briefing, 
the Deputy Assistant Secretary of State for Counter Threat Finance and 
Sanctions reported that he had traveled to Asia and Europe to talk 
with representatives from smelters and governments about responsible 
sourcing initiatives and encourage participation in such initiatives. 
State officials also indicated that they have facilitated outreach 
efforts for industry associations, such as the Conflict-Free Smelter 
Initiative (CFSI) and others, to help them secure meetings in Asian 
countries to discuss conflict free mining and smelting. According to 
the State officials, during the outreach some members from industry 
and industry associations expressed interest in talking to Commerce 
about smelters and support for responsible sourcing, according to 
State officials. 

* Commerce officials stated that their proposed outreach plan 
identified entities that could enable them to develop the list of 
conflict mineral smelters and refiners required by the Act. According 
to these officials, they have conducted outreach to these entities, 
including government agencies, industry associations, international 
organizations, and NGOs. 

U.S. Agency Technical Assistance: 

Some U.S. agencies have provided technical assistance related to 
responsible sourcing of conflict minerals to various stakeholders. 
According to agency officials, these stakeholders have consisted 
primarily of other governments, particularly in the Great Lakes 
Region. For example: 

* State officials said that they had shared experiences and challenges 
related to implementing the Act with officials from the EU who were 
working on proposed conflict minerals legislation. 

* SEC officials stated that they had discussed with EU officials 
issues that SEC considered when drafting the conflict minerals rule as 
well as questions about the rule that SEC received from industry. 

* USAID officials stated that they had been working with the ICGLR in 
providing technical assistance on conflict minerals programs, 
particularly through the steering committee for ICGLR's Regional 
Initiative against the Illegal Exploitation of Natural Resources. 
[Footnote 38] Specifically, according to USAID officials, USAID has 
been implementing a multiyear institutional capacity program in 
support of the ICGLR to build the overall strength of the Executive 
Secretariat as well as the ICGLR's regional initiative. USAID 
officials said that the agency will soon begin implementing activities 
to support a third-party supply chain audit mechanism and an 
independent conflict minerals supply chain auditor. 

Stakeholder Initiatives Are Expanding and Provide Some Information on 
Sourcing of Conflict Minerals: 

Since we reported in July 2013,[Footnote 39] stakeholders have 
expanded existing initiatives and added new initiatives focused on 
responsible sourcing of conflict minerals in the DRC and adjoining 
countries, to include new mine sites, countries, and smelters. Some of 
these initiatives have yielded publicly available information, 
including data on production of conflict-free minerals and export 
data, as well as reports on the progress and results of the 
initiatives. However, this information is limited in scope and thus 
may not provide a comprehensive description of the sourcing of 
conflict minerals from the DRC and adjoining countries. 

Stakeholders Have Expanded Existing Initiatives, and New Initiatives 
Are Underway: 

Stakeholders have recently expanded, or made plans to expand, a number 
of existing global and in-region responsible sourcing initiatives; and 
two new initiatives are underway. Figure 3 shows the starting dates 
for existing, expanding, and new responsible sourcing initiatives. 
According to some stakeholders we interviewed, improvement in security 
in eastern DRC and industries' growing awareness of responsible 
sourcing and the Act's requirements may account for the expansion of 
responsible sourcing initiative. 

Figure 3: Timeline of the Starting Dates of Stakeholder-led 
Initiatives from 2008 to June 2014: 

[Refer to PDF for image: timeline] 

2008: 
Conflict-Free Sourcing Initiative; 
German Federal Institute for Geosciences and Natural Resources (BGR) 
Certified Trading Chains. 

2009: 
ITRI Tin Supply Chain Initiative. 

2010: 
July: Dodd-Frank Wall Street Reform and Consumer Protection Act passed; 
ICGLR Regional Certification Mechanism; 
Kemet Partnership for Social and Economic Sustainability; 
OECD Due Diligence Guidance; 
Responsible Jewellery Council Chain-of-Custody Certification Program; 

2011: 
Public-Private Alliance (PPA) for Responsible Minerals Trade; 
Solutions for Hope. 

2012: 
August 22: Security Exchange Council (SEC) adopts Conflict Minerals 
Rule; 
Conflict Free Tin Initiative; 
London Bullion Market Association Responsible Gold Program; 
Partnership Africa Canada Conflict Free Gold; 
World Gold Council Conflict-Free Gold Standard; 

2013: 
Better Sourcing Program; 
BGR Analytical Fingerprint Lab. 

2014: 
May 31: First conflict minerals disclosures due to SEC. 

Source: GAO analysis. GAO-14-575. 

[End of figure] 

Some Existing Global Initiatives Are Expanding: 

The following are examples of global responsible-sourcing initiatives 
that stakeholders have expanded since we reported in July 2013. 
[Footnote 40] 

Conflict-Free Sourcing Initiative: 

The Conflict-Free Sourcing Initiative (CFSI) has expanded in several 
aspects related to responsible sourcing.[Footnote 41] First, CFSI's 
Conflict-Free Smelter Program has expanded the number of smelters it 
has certified as conflict free. The program is a voluntary one in 
which smelters undergo an independent third-party audit, in accordance 
with OECD's due diligence guidelines, to verify the origin of minerals 
processed at their facilities. The number of smelters that the program 
has certified as conflict-free has expanded from 26 smelters in summer 
2013 to 85 smelters as of April 25, 2014 (see table 1). An additional 
25 smelters are in the process of being certified, bringing the total 
number of smelters involved in the program to 110.[Footnote 42] As of 
January 2014, the Conflict-Free Smelter Program has expanded to 
include smelters for tungsten in addition to the other three conflict 
minerals. 

Table 1: Number of Smelters and Refiners in the Conflict-Free Smelter 
Program as of April 25, 2014: 

Mineral: Tantalum; 
Number of certified smelters/refiners: 28; 
Number of smelters/refiners working toward certification: 1; 
Total: 29. 

Mineral: Tin; 
Number of certified smelters/refiners: 13; 
Number of smelters/refiners working toward certification: 14; 
Total: 27. 

Mineral: Tungsten; 
Number of certified smelters/refiners: 1; 
Number of smelters/refiners working toward certification: 8; 
Total: 9. 

Mineral: Gold; 
Number of certified smelters/refiners: 43; 
Number of smelters/refiners working toward certification: 2; 
Total: 45. 

Mineral: Total; 
Number of certified smelters/refiners: 85; 
Number of smelters/refiners working toward certification: 25; 
Total: 110. 

Source: Conflict-Free Sourcing Initiative data, GAO (analysis). GAO-14-
575. 

[End of table] 

Second, according to CFSI representatives, through outreach to 
industry, CFSI has expanded its collaboration with companies involved 
with the conflict minerals supply chain. CFSI's outreach includes 
twice-yearly workshops on conflict minerals issues that are open to 
all participants. According to CFSI, outreach such as these workshops 
bring together hundreds of representatives from industry, government, 
and civil society for updates, in-depth discussions, and guidance on 
best practices for responsible mineral sourcing.[Footnote 43] CFSI 
officials stated that such outreach recently resulted in collaboration 
with the tungsten industry, which led to certification of the first 
conflict-free tungsten smelter in 2014. 

Third, in 2014, CFSI began offering its members information about the 
SEC-required "reasonable country of origin" data for conflict 
minerals, providing the most detailed information currently available 
about the source of conflict minerals for smelting and refining 
facilities that are validated through the Conflict-Free Smelter 
Program. According to CFSI, this information may be useful to 
companies as they prepare the conflict minerals disclosure reports 
required by the SEC rule and demonstrate conformance with the OECD due 
diligence guidelines. 

Responsible Gold Program: 

In January 2012, the London Bullion Market Association (LBMA), which 
represents the global market for gold and silver, finalized and 
published its Responsible Gold Guidance to ensure that the gold 
refiners it accredits purchase only conflict-free gold.[Footnote 44] 
The refiners accredited by LBMA are required to complete an annual 
third-party audit to verify their compliance with the LBMA guidance, 
according to an LBMA official. As of March 2014, of the 67 gold 
refiners that LBMA oversees, more than three-quarters had successfully 
submitted their audits and received the Responsible Gold Certificate, 
according to the official. The representative stated that if a refiner 
does not submit a third-party audit by the end of 2014, the refiner 
will be removed from LBMA's list of accredited refiners. An LBMA 
official said that the association also collaborates with other 
responsible sourcing stakeholders and global gold exchanges and works 
closely with OECD. For example, the official said that, working 
through OECD, LBMA has met with Chinese industry representatives to 
clarify the purpose and benefits of conducting due diligence audits of 
their refiners. 

Responsible Jewellery Council Chain-of-Custody Certification Program: 

The Responsible Jewellery Council--a diamond and precious metals 
industry association--launched a chain-of-custody certification 
program in March 2012 to help its member companies identify and track 
conflict-free gold throughout their supply chains.[Footnote 45] The 
program's requirements, which are aligned with the OECD Due Diligence 
Guidance for gold, include a third-party audit of each certified 
entity to ensure that its gold is conflict-free, according to the 
Responsible Jewellery Council. According to an official with the 
Responsible Jewellery Council, this certification can support 
companies' compliance with the Dodd Frank Act. As of April 2014, nine 
entities had been validated under the council's certification program 
and more entities were in the process of being certified, according to 
the official.[Footnote 46] 

Some In-Region Initiatives Have Also Expanded: 

The following are examples of in-region responsible sourcing 
initiatives that stakeholders have expanded, or made plans to expand, 
since we reported in July 2013. 

ITRI Tin Supply Chain Initiative: 

The ITRI Tin Supply Chain Initiative (iTSCi) recently announced that 
it is expanding its in-region operations. The initiative works with 
"upstream" entities (i.e., companies involved in the conflict minerals 
supply chain from mine to smelter) in instituting the actions, 
structures, and processes necessary to conform with the OECD Due 
Diligence Guidance and helps relevant U.S. companies report on their 
due diligence efforts to the SEC as required by the Dodd-Frank 
Act.[Footnote 47] The assistance that iTSCi provides includes a system 
to trace bags of minerals from the mines to the exporter, due 
diligence audits of iTSCi's member companies, and assessments of the 
political and security situations, which have been conducted at 
various mine sites in the DRC and Rwanda. 

In February 2014, iTSCi announced that it was expanding its 
traceability program into a remote area in the northern region of the 
Maniema province of the DRC, and into the North Kivu province of the 
DRC. According to iTSCi, improved security in North Kivu, which has a 
history of armed conflict, accounts in part for the expansion into the 
province. An iTSCi official stated that the initiative is currently 
looking at options for extending into South Kivu. Additionally, in 
April 2014, iTSCi announced that the program had started operations in 
Burundi. According to iTSCi, there is presently little evidence of 
activity by nongovernment armed groups in Burundi, since there have 
been no reports that armed groups are controlling mine sites or 
transportation routes, extorting money or minerals, or illegally 
taxing the trade of minerals. iTSCi further reported that it may 
extend the program to Uganda and eventually to the entire Great Lakes 
Region. Also, an iTSCi official stated that the initiative had 
successfully piloted technology in Rwanda to collect and manage data 
on conflict minerals electronically, which would replace the current 
paper-based system and increase efficiency of data collection. 

Solutions for Hope: 

Launched by Motorola Solutions and AVX in 2011, the Solutions for Hope 
tantalum program is a "closed-pipeline" initiative that traces the 
flow of tantalum from the mine to the end-use company.[Footnote 48] In 
June 2013, Solutions for Hope reported that it had completed six 
shipments of tantalum, totaling more than 145 metric tons, from the 
Katanga province in the DRC. According to officials, in part because 
of improved security in the province, the initiative started sourcing 
tantalum from North Kivu in March 2014. Officials also noted that 
Solutions for Hope is exploring a closed pipeline system for gold in 
the DRC. 

Conflict-Free Tin Initiative: 

The Conflict-Free Tin Initiative (CFTI), a multistakeholder effort 
supported by the Netherlands government, is a closed-pipeline 
initiative, similar to Solutions for Hope, started in October 2012 for 
sourcing tin from the South Kivu province of the DRC. According to 
CFTI, the initiative has expanded its mining operation to Maniema, a 
province bordering South Kivu, which is less prone to conflict and the 
government is reinvesting tax income into the mining communities. 
According to USAID, a CFTI stakeholder, from October 2012 to December 
2013, the initiative generated a total export value of more than $3 
million. 

Regional Certification Mechanism: 

In 2010, the International Conference on the Great Lakes Region 
(ICGLR) began working with an NGO to develop a regional certification 
mechanism to ensure that conflict minerals are fully traceable. 
ICGLR's Regional Certification Mechanism (RCM) enables member 
countries and their mining companies to demonstrate where and under 
what conditions minerals were produced, allowing member governments to 
issue ICGLR regional certificates for those mineral shipments that are 
in compliance with the standards of the mechanism. The ICGLR issued 
its first certificate in November 2013 to a mine in Rwanda. According 
to an ICGLR official, the DRC launched its certificate program but had 
not yet issued any certificates as of November 2013. He added that 
Tanzania and Burundi may be able to issue certificates by the end of 
2014. The ICGLR official noted several challenges in instituting the 
RCM in the DRC and the region. For example, he cited that it is 
logistically difficult to catalogue all mines in each country. In 
addition, the official noted that training local officials to use the 
RCM software is difficult and time consuming. The official added that 
it takes member countries 1 year to prepare for all components 
associated with launching the RCM. 

New Initiatives Have Launched in the Region Since 2013: 

In the past year, one existing stakeholder has launched a new in-
region responsible sourcing initiative and a new stakeholder has 
established an initiative. 

Analytical Fingerprint Project: 

The German government's Federal Institute for Geosciences and Natural 
Resources (BGR), an existing stakeholder, launched a new initiative in 
the past year. According to a representative, BGR's primary role is to 
support the region's governments and to build government capacity. 
Since 2013, BGR has initiated the Analytical Fingerprint Project to 
allow for independent verification of the origin of the conflict 
mineral by comparing the composition of tantalum, tin, and tungsten 
concentrate samples of a known origin with unknown samples, similar to 
a DNA test. According to a BGR official, the project has three types 
of units--sample preparation labs, high tech labs, and a management 
unit. To date, BGR has established sample preparation labs, located in 
Rwanda since 2013 and in the DRC since 2014, where mineral ore samples 
are prepared for analysis. A third sample preparation lab is under 
construction in Burundi. BGR is in negotiations to establish a high 
tech lab in Tanzania, which receives and analyzes the samples from the 
preparation labs. Additionally, in 2013, according to a BGR official, 
BGR established a project management unit at the ICGLR headquarters in 
Burundi, which evaluates the raw data and produces the analytical 
fingerprints. 

Better Sourcing Program Responsible-Sourcing Pilot: 

The Better Sourcing Program (BSP), a private company that offers an 
independently audited due diligence assurance program to enable 
companies to source tantalum, tin, tungsten, and gold from the region, 
is a new stakeholder in the region in 2013. The Better Sourcing 
Program established a pilot program that covers a tantalum supply 
chain originating from the Republic of the Congo (also known as Congo-
Brazzaville), which is the first responsible-sourcing initiative in 
that country. Better Sourcing Program officials stated that they chose 
to pilot the initiative in the Republic of the Congo because no other 
scheme to support producers existed there, because the country is 
relatively conflict free, and because the government has been 
cooperative. 

Stakeholders Face Operational Challenges in Expanding or Launching In-
Region Initiatives: 

Some stakeholders that we interviewed noted various challenges to 
expanding or launching responsible-sourcing efforts in the DRC and 
adjoining countries. For example: 

* Lack of infrastructure. Some stakeholders reported that inadequate 
infrastructure in the DRC and adjoining countries affects their 
ability to operate in the region and expand initiatives to new areas. 
Representatives from Solutions for Hope stated that infrastructure in 
the DRC cannot support a large-scale smelter. According to these 
representatives, the power supply in the DRC can be inconsistent and, 
because smelting facilities require a large, consistent power supply 
to function properly, all tin, tantalum, and tungsten currently are 
exported from the DRC and Rwanda for smelting.[Footnote 49] 

* Lack of government support. Some stakeholders reported some 
operational challenges related to the region's national and provincial 
governments. For example, stakeholders involved in the Conflict Free 
Tin Initiative stated that sales of tin from their mine in South Kivu 
were halted for nearly 2 months in 2013 after the provincial 
government of the region imposed harsh taxes on the minerals mined 
there. Additionally, Solutions for Hope officials reported that the 
DRC's current tax structure is not conducive to legitimizing gold and 
that expanding the initiative to include gold is therefore difficult. 

* Lack of buyers for conflict minerals from conflict zones. Several 
stakeholders and agency officials reported that some companies are 
reluctant to buy minerals produced in the DRC and adjoining countries 
because of the high cost of the due diligence required by the Dodd-
Frank Act and the perceived reputational risk. For example, according 
to one industry official, a major challenge to responsible sourcing in 
the region is that the cost of complying with the SEC rule makes it 
difficult for SEC-reporting companies to compete in the global market 
against companies that are not required to perform costly due 
diligence. In addition, an official from the Responsible Jewellery 
Council noted that gold is mined in many locations around the world 
and that production costs must always be taken into account. She 
stated that because the cost of due diligence for gold is usually 
proportional to risk, mining and sourcing responsibly in the Great 
Lakes Region could become more expensive than in other, lower-risk 
areas and that this represents a challenge to responsible sourcing 
efforts in the region. 

Some Information about the Conflict Minerals Trade Is Publicly 
Available: 

Some stakeholders and governments in the region provide publicly 
available information related to in-region mining of conflict minerals 
and responsible sourcing initiatives. According to industry officials, 
the amount of publicly available data reported by responsible sourcing 
initiatives has increased over the past year. We found that iTSCi 
publishes various reports on its public website as part of its due 
diligence system for its members. These reports provide production and 
export data for tin, tantalum, and tungsten, including amounts traced 
through the iTSCi program, from three provinces in the DRC and Rwanda, 
as well as the mineral sales in U.S. dollars (for more details, 
including the applicable quantitative data, see appendix IV). Also on 
its website, iTSCi publishes third-party audits of member companies, 
which assess the extent to which the companies have implemented the 
OECD Due Diligence Guidance and evaluate the companies' adherence to 
iTSCi's traceability and due diligence procedure. Additionally, iTSCi 
publishes governance assessments covering a range of topics. Examples 
include the security and political situation in areas without an iTSCi 
presence and the risks and performance, relative to the OECD Due 
Diligence Guidance and the SEC rule, of stakeholders that are part of, 
or play a role in monitoring, the conflict minerals supply chain. 
[Footnote 50] 

A comparison of production data from the conflict-free sourcing 
initiatives in the context of each country's or the region's total 
production or exports of tin, tantalum, tungsten, or gold is not 
feasible, because no reliable, comprehensive data on the production or 
export of conflict minerals for the countries or region are available. 
However, some quantitative government data on the production and 
exports of conflict minerals from the DRC and adjoining countries are 
available (see appendix V). For example, the DRC government has 
published data on production and exports of all four conflict minerals 
and the Rwandan government has published export and value data for 
tin, tantalum, and tungsten. In addition, the International Trade 
Centre, a joint agency of the World Trade Organization and the UN, 
collects export data from governments that provide some context for 
the amount of conflict minerals declared as exported from the region, 
although these data do not identify minerals from conflict-free mines 
(see appendix VI). 

Some stakeholders indicated that the ICGLR may, at some point, be able 
to provide production and export data of conflict minerals from its 
member states, mostly Dodd-Frank-affected countries. This information 
could increase transparency at the individual country level. ICGLR 
requires its member states to implement a chain-of-custody tracking 
system for conflict minerals and to transmit data on mineral flows 
(i.e., quantities and destinations) at regular intervals to be 
incorporated in the ICGLR Regional Mineral Tracking Database. 
According to an ICGLR official, this database is populated with three 
types of information: (1) a historical record of mine sites in each 
country, (2) types and quantities of minerals produced at each mine 
site, and (3) mineral flows from the mine sites. According to ICGLR 
documentation, the data are used to track, analyze, and reconcile 
regional mineral flows and will become publicly available to ensure 
ICGLR's credibility. In November 2013, the ICGLR official stated that 
four of the 12 member countries had submitted information for the 
regional database: Rwanda, Uganda, the DRC, and, to a lesser extent, 
Burundi. 

Little Additional Information on Rate of Sexual Violence in Eastern 
DRC and Adjoining Countries since July 2013: 

Since we reported in July 2013, no new population-based surveys 
related to sexual violence in the DRC, Uganda, Rwanda, or Burundi have 
been published. However, population-based surveys are underway, or 
being planned, in three of those countries--the DRC, Burundi, and 
Rwanda. In addition, some new case file data on sexual violence are 
available for all four countries. However, as we reported in 2011, 
case file data on sexual violence are not suitable for estimating a 
rate of sexual violence. 

Several Population-Based Surveys Are Underway or Planned: 

Although no new surveys related to sexual violence in the DRC, Uganda, 
Rwanda, or Burundi have been published since July 2013, population-
based surveys in the DRC, Burundi, and Rwanda are underway or planned 
by ICF International.[Footnote 51] According to ICF International, 
data collection for a Demographic and Health Survey (DHS), which is a 
type of population-based survey, for the DRC is complete, but data 
resulting from the survey are not expected until September 2014 or 
later. ICF International also said that fieldwork for a DHS in Rwanda 
is likely to start in September or October 2014. ICF International 
indicated that a DHS is planned to start in Burundi in 2014; however, 
data collection may be delayed by funding gaps and, as a result, the 
survey may not take place until 2015. 

Figure 4 shows the anticipated timelines for the population-based 
surveys on sexual violence that are currently underway or planned in 
the DRC, Burundi, and Rwanda. It also shows the publication dates for 
eight population-based surveys that provided data on the rate of 
sexual violence in eastern DRC, Rwanda, and Uganda that have been 
published since we started reporting on sexual violence in the region 
in 2011. 

Figure 4: Timeline of Population-Based Surveys Estimating the Rate of 
Sexual Violence in Eastern DRC, Rwanda, Uganda, and Burundi: 

[Refer to PDF for image: timeline] 

Publication date: 

Democratic Republic of the Congo (DRC): 
DRC Ministry of Planning: 2009; 
DRC Ministry of Planning: 2009; 
McGill University: 2010; 
expected to publish Demographic and Health Survey (DHS): 2015 or 
beyond. 

Rwanda: 
DHS: 2010; 
IMAGES survey: 2010; 
DHS planned to start: 2014. 

Uganda: 
Uganda Bureau of Statistics: 2007; 
University of California Berkeley: 2010; 
DHS: 2012. 

Burundi: 
DHS planned to start: 2014. 

Source: GAO analysis. GAO-14-575. 

[End of figure] 

Some Additional Case File Data on Sexual Violence Have Become 
Available since GAO's 2013 Report: 

Since 2013, some U.S. and UN agencies as well as researchers and an 
NGO have provided additional case file data on instances of sexual 
violence in the DRC and adjoining countries. In February 2014, State 
submitted its annual country reports on human rights practices to 
Congress, which provided the following data pertaining to sexual 
violence in the DRC, Burundi, and Uganda.[Footnote 52] For example, 

* In the DRC, the government reported 18,729 cases of sexual violence 
in 2012. 

* In Burundi, 3,781 cases of gender-based violence were reported in 
2010, according to a report compiled from family development centers 
throughout the country. 

* In Uganda, 530 cases of rape were registered in 2012, and 301 of the 
alleged rapists were tried and convicted. 

In addition, some UN entities reported case file information. For 
example: 

* MONUSCO reported that between October 1, 2013, and December 5, 2013, 
it recorded acts of sexual violence against at least 79 women and 28 
girls in conflict-affected provinces in the DRC.[Footnote 53] 

* MONUSCO reported in March 2014 that sexual violence crimes continued 
to be committed by armed groups and that such crimes were allegedly 
committed against at least four women, 35 girls, and one man by 
elements of illegal armed forces and members of the Congolese military 
and police in January 2014. 

* The United Nations Joint Human Rights Office reported in April 2014 
that between the period of January 2010 and December 2013, it 
registered 3,635 victims of sexual violence throughout the DRC. 
[Footnote 54] The report indicated that, for the reporting period, 
while more than half of the total alleged acts of sexual violence were 
committee by illegal armed groups, members of the Congolese national 
military committed less than half of the other alleged acts. 

Moreover, the DRC government reported case file information. For 
example: 

* A report published in June 2013 by the DRC Ministry of Gender, the 
Family, and Child, with support by the UN Population Fund, highlighted 
cases of sexual violence in seven provinces in the country: Bandundu, 
Bas Congo, Katanga, Kinshasa, North Kivu, Orientale, and South Kivu. 
[Footnote 55] Data in the report indicate that 10,322 incidents of 
sexual and gender-based violence were reported for the seven provinces 
in 2011 and that the number increased to 15,654 incidents in 2012. 
While the data also indicate that most of these assaults were 
committed by people dressed in civilian clothes--85 percent in 2011 
and 78 percent in 2012--incidents involving armed groups between 2011 
and 2012 increased in South Kivu from 36 to 76 percent, respectively, 
and in North Kivu from 32 to 61 percent, respectively. 

An NGO also published case file information. For example: 

* Médecins sans Frontières reported in March 2014 that in 2012 it 
provided medical care to a total of 4,037 women, men, and children 
after incidents of sexual violence in different project locations in 
the DRC.[Footnote 56] It reported treating, in a 5-week period in late 
2012 through early 2013, 95 of those individuals in one camp for 
Internally Displaced People in North Kivu. 

Several factors make case file data unsuitable for estimating rates of 
sexual violence. 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 surveys, time frames, locales, and definitions of sexual 
violence may 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. 

Conclusions: 

The long-running humanitarian crisis in eastern DRC, one of the most 
volatile areas in Africa, continues to be a concern for the U.S. 
government and the international community. As we have previously 
reported, section 1502 of the Dodd-Frank Wall Street Reform and 
Consumer Protection Act, enacted in 2010, is part of the U.S. effort 
to address the perpetration of sexual violence and mass killings in 
the DRC by armed groups who profit from the exploitation and trading 
of conflict minerals. We have compiled stakeholder data on the 
production and trade of conflict minerals that demonstrates, to some 
extent, the degree of transparency related to the conflict minerals 
trade. The actions undertaken by U.S. agencies in response to the Act 
could facilitate SEC-reporting companies' compliance with the SEC 
rule, promulgated pursuant to the Act, as they conduct due diligence 
and prepare the required annual reports disclosing the use and the 
origin of conflict minerals in their products. However, because 
Commerce has not met the Act's requirement that it compile by January 
2013 a list of smelters and refiners--considered the "choke point" of 
the conflict minerals supply chain--these companies lack a source of 
critical information about the conflict minerals supply chain. Some 
stakeholders indicated that a comprehensive list of conflict minerals 
smelters and refiners could enable companies that are subject to the 
SEC rule to maintain transparency of the supply chain, and also 
provide companies the information they need for their SEC-required 
conflict minerals disclosure reports. Commerce cited several 
challenges that have hindered its providing the required list to 
Congress. However, having an action plan with associated timeframes 
could better position Commerce to report on the status of its efforts 
to produce a final list and provide it to Congress and to hold its 
personnel accountable for completing related activities. 

Recommendation for Executive Action: 

To give Congress a sense of Commerce's efforts to produce a listing of 
all known conflict minerals processing facilities worldwide, as 
required by section 1502 of the Dodd-Frank Wall Street Reform and 
Consumer Protection Act, we recommend that the Secretary of Commerce 
provide to Congress a plan that outlines the steps, with associated 
timeframes, to develop and report the required information about 
smelters and refiners of conflict minerals worldwide. 

Agency and Third Party Comments and Our Evaluation: 

We provided a draft of this report to SEC, State, USAID, and Commerce 
for their review. Commerce provided written comments, which we have 
reproduced in appendix VII. SEC and State provided technical comments, 
which we incorporated as appropriate. We also provided relevant 
portions of the draft report to some industry associations and other 
stakeholders of conflict minerals initiatives from whom we had 
obtained information during our review; some of these stakeholders 
provided technical comments that we incorporated as appropriate. 

In its written comments, Commerce noted in response to our 
recommendation that it had provided and briefed us on a detailed 
outreach action plan that set forth how it intended to assemble the 
list of conflict minerals processing facilities required by the Act. 
However, as we have noted in this report, the document that Commerce 
provided was an outreach plan, consisting of a list of stakeholders 
that Commerce intended to contact to obtain information on conflict 
minerals smelters and refiners. The plan did not indicate a timeframe 
for completing and submitting to Congress the required listing of 
conflict minerals processing facilities worldwide. Commerce concurred 
with our recommendation and noted that it will submit a listing of all 
known conflict minerals processing facilities worldwide to Congress by 
September 1, 2014. 

We are sending copies of this report to appropriate congressional 
committees. The report is also available at no charge on the GAO 
website at [hyperlink, http://www.gao.gov/]. 

If you or your staffs 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 VIII. 

Signed by: 

Kimberly M. Gianopoulos: 
Acting Director, International Affairs and Trade: 

List of Addressees: 

The Honorable Barbara Mikulski: 
Chairwoman: 
The Honorable Richard Shelby: 
Vice Chairman: 
Committee on Appropriations: 
United States Senate: 

The Honorable Tim Johnson: 
Chairman: 
The Honorable Mike Crapo: 
Ranking Member: 
Committee on Banking, Housing, and Urban Affairs: 
United States Senate: 

The Honorable Ron Wyden: 
Chairman: 
The Honorable Orrin G. Hatch: 
Ranking Member: 
Committee on Finance: 
United States Senate: 

The Honorable Robert Menendez: 
Chairman: 
The Honorable Bob Corker: 
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: 

The Honorable Jeb Hensarling: 
Chairman: 
The Honorable Maxine Waters: 
Ranking Member: 
Committee on Financial Services: 
House of Representatives: 

The Honorable Ed Royce: 
Chairman: 
The Honorable Eliot Engel: 
Ranking Member: 
Committee on Foreign Affairs: 
House of Representatives: 

The Honorable Dave Camp: 
Chairman: 
The Honorable Sander Levin: 
Ranking Member: 
Committee on Ways and Means: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

To determine the extent, if any, to which relevant U.S. agencies have 
engaged in activities related to responsible sourcing of conflict 
minerals, we interviewed officials who are cognizant of conflict 
minerals issues from the Departments of Commerce and State (State) and 
the United States Agency for International Development (USAID), and 
the Securities and Exchange Commission (SEC). We reviewed Section 1502 
of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Pub. 
L. No. 111-203) to identify the requirements for Commerce, State, SEC, 
and USAID related to implementation of section 1502. We also reviewed 
and analyzed reports and other documents from the agencies, such as 
the U.S. Strategy to Address the Linkages Between Human Rights Abuses, 
Armed Groups, Mining of Conflict Minerals, and Commercial Products; 
the conflict minerals rule; and maps of mineral-rich zones and areas 
under control of armed groups in the DRC. In addition, we reviewed and 
analyzed press releases, statements, plans, and guidance pertaining to 
conflict minerals and responsible sourcing that were issued by U.S. 
agencies. We also reviewed notes and agendas of responsible sourcing 
forums and other meetings attended by U.S. officials. 

To analyze what is known about the status of, and any information 
provided by, initiatives focused on responsible sourcing of conflict 
minerals from the DRC and adjoining countries, we interviewed 
officials and reviewed and analyzed documents from State, USAID, and 
the United Nations Group of Experts on the Democratic Republic of the 
Congo (UNGoE); interviewed representatives and reviewed and analyzed 
guidance documents, reports, and presentations from foreign 
government, industry associations, multilateral organizations, 
companies, and nongovernmental organizations (NGOs). We selected these 
stakeholders based on their expertise on responsible sourcing issues, 
because they represented a range of perspectives on conflict minerals, 
and because we had established contacts with these entities on our 
last review.[Footnote 57] In addition, some of the stakeholders we 
talked to have been working on the ground in the DRC. The stakeholders 
we spoke with constitute a nongeneralizable sample, and the 
information we gathered from them cannot be used to infer views of 
other stakeholders cognizant of conflict minerals issues. To determine 
which initiatives had expanded and which were new initiatives in the 
region, we interviewed U.S. agency officials and relevant stakeholders 
and reviewed documentation from initiatives in the region. This report 
covers initiatives on which we have previously reported and new 
initiatives since our 2013 report, as described by stakeholders we 
interviewed.[Footnote 58] However, it is possible that the agency 
officials and stakeholders with whom we spoke may be unaware of other 
stakeholders and/or responsible sourcing initiatives active in the DRC 
and region. To determine the starting dates of the initiatives, we 
interviewed stakeholders and reviewed the websites of the various 
initiatives. To demonstrate what information stakeholders have 
reported regarding responsible sourcing initiatives, we reviewed and 
analyzed information published on the websites associated with the 
various responsible sourcing initiatives. When reporting on 
information provided by the initiatives and stakeholders, we are 
referring to information such as reports published, amount of minerals 
mined per region/country, amount of minerals exported, and value of 
minerals produced and exported, including data covering 2012 through 
2014. The information gathered cannot be generalized and cannot be 
used to infer views of other stakeholders cognizant of conflict 
minerals issues. 

To demonstrate other sources of publicly available data on conflict 
minerals, we collected and analyzed stakeholder and government data 
covering 2003 through 2014. Because the data were not used to support 
findings, conclusions, or recommendations, we did not assess their 
reliability. To demonstrate the output of one of the in-region 
initiatives, we collected production and export data for the ITRI 
Supply Chain Initiative (iTSCi). We reviewed the production reports 
for three provinces in the DRC and for Rwanda published on iTSCi's 
website, abbreviated the data to include those most relevant to this 
study, and converted the data to tons and thousands of U.S. dollars. A 
limitation of the data is that the disaggregated production data-by 
mineral and mine-are proprietary to iSTCi members, so it is not 
possible to quantify the total amount of any of the minerals 
separately. We also collected conflict mineral production and export 
data from the websites of the governments of the DRC and Rwanda and 
from the International Trade Centre. We are presenting these data in 
the appendixes of the report because these are the only publicly 
available data we found for sourcing conflict minerals from the 
region. There is no distinction in these data between minerals that 
are conflict-free and those that have supported armed groups. 
Moreover, none of these data can be generalized or be used to infer 
the total production or export of conflict minerals from the DRC and 
the adjoining countries. 

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 the DRC--Rwanda, Uganda, 
and Burundi--since our 2013 report on sexual violence in these areas. 
[Footnote 59] During the course of our review, we interviewed 
officials from State and USAID and interviewed NGO representatives and 
researchers to discuss the collection of sexual violence-related data--
including population-based surveys and case file data--in the DRC and 
adjoining countries. Specifically, we followed up with researchers and 
representatives from those groups we interviewed for our prior review 
on sexual violence rates in eastern DRC and adjoining countries, 
including a representative from the Human Rights Center at the 
University of California, Berkeley, School of Law and others 
officials. The team also traveled to New York City to meet with 
officials from the United Nations Population Fund, United Nations High 
Commissioner for Refugees, and the United Nations Special 
Representative of the Secretary-General on Sexual Violence in 
Conflict. We also conducted Internet literature searches to identify 
new academic articles containing any additional information on sexual 
violence since our 2013 report.[Footnote 60] 

We conducted this performance audit from September 2013 to June 2014 
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. 

[End of section] 

Appendix II: State Department Map of Armed Groups Present at Mine 
Sites in the Democratic Republic of the Congo: 

Figure 5 depicts the most recent map published by the Department of 
State. The map focuses on the exploitation of tin, tantalum, tungsten, 
and gold in the provinces of North and South Kivu and parts of 
Orientale, Maniema, and Katanga provinces. 

Figure 5: State Department Map of the Presence of Armed Groups at Mine 
Sites in the Democratic Republic of the Congo, as of February 2014: 

[Refer to PDF for image: map with associated information] 

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer 
Protection Act, Fiscal Year 2010, Public Law 111-203, enacted on July 
21, 2010, states that “the Secretary of State shall, in accordance 
with the recommendation of the United Nations Group of Experts on the 
Democratic Republic of the Congo in their December 2008 report—(i) 
produce a map of mineral-rich zones, trade routes, and areas under the 
control of armed groups in the Democratic Republic of the Congo (DRC) 
and adjoining countries based on data from multiple sources, including—
(I) the United Nations Group of Experts on the Democratic Republic of 
the Congo; (II) the Government of the Democratic Republic of the 
Congo, the governments of adjoining countries, and the governments of 
other Member States of the United Nations; and (III) local and 
international nongovernmental organizations.” This map was compiled by 
the U.S. Department of State to submit to the Committees on 
Appropriations, Foreign Affairs, Ways and Means, and Financial 
Services of the House of Representatives, and the Committees on 
Appropriations, Foreign Relations, Finance, and Banking, Housing, and 
Urban Affairs of the Senate. The map focuses on exploitation of gold, 
cassiterite, wolframite, and columbitetantalite (coltan) in the 
provinces of North Kivu and South Kivu, and parts of Orientale, 
Maniema, and Katanga provinces. The map is based on data from surveys 
conducted in 2013 by a non-governmental organization, the 
International Peace Information Service (IPIS). IPIS and the DRC 
government launched a capacity-building project in early 2013 focused 
on mine site monitoring, data collection, and mapping. The Department 
will continue to draw on data from this project for future iterations 
of this map, and has consulted the DRC government, the Group of 
Experts, and MONUSCO regarding the current map. 

Lack of complete of fully verifiable data makes it difficult to 
confirm the location of many mine sites; to establish which mines are 
active and which are inactive at any given time; and to 
comprehensively verify the armed groups or other entities that are 
either present at mines or have access to revenue streams emanating 
from them. These conditions change frequently and were complicated by 
heightened conflict in 2013, in particular between the Congolese armed 
forces (FARDC) and the M23 rebel group. FARDC units and other state 
security forces are deployed throughout the eastern provinces, and 
according to the Group of Experts and other sources, some elements of 
the state security forces continue to engage in illegal extortion or 
control of the mineral trade. 

There are hundreds of mining sites in North and South Kivu alone, 
nearly all of which are artisanal mines (dug by hand with basic 
tools), and the majority of which are very small scale operations that 
operate intermittently. Many of the mining sites in eastern DRC are 
inaccessible to outsiders due to remoteness, a lack of passable roads, 
and the dangers stemming from the presence of militia, undisciplined 
army troops, and bandits. A comprehensive mapping study that applies a 
consistent methodology within a single timeframe to the entirety of DRC’
sconflict-affected eastern provinces and adjacent countries has not 
been conducted. Companies, trade associations, governments, and other 
stakeholders involved in the minerals trade should thus continue to 
obtain additional data through their own channels, as recommended in 
the guidance on due diligence adopted by the Organization for Economic 
Cooperation and Development (OECD) and cited by the U.S. Securities 
and Exchange Commission. 

In light of the above, this map should not by itself be considered a 
source of sufficient information to serve as a substitute for the 
exercise of effective due diligence on mineral supply chains. 

Source: State. GAO-14-575. 

[End of figure] 

[End of section] 

Appendix III: SEC Flowchart Summary of the Disclosure Process for the 
Final Conflict Minerals Rule: 

When the SEC adopted the conflict minerals rule in August 2012, it 
published a flowchart summary of the final rule to guide SEC-reporting 
companies affected by the rule through the disclosure process (see fig 
6). In general, the process reflects that an SEC-reporting company 
needs to (1) determine whether its manufactured products contain 
conflict minerals, (2) determine whether conflict minerals are 
necessary to the functionality or production of the product and if it 
originated in the DRC or an adjoining country, and (3) possibly 
conduct due diligence and potentially provide a Conflict Minerals 
Report. 

Figure 6: SEC Flowchart Summary of Conflict Minerals Rule: 

[Refer to PDF for image: flow chart] 

Start: 

1. Does the issuer file reports with the SEC under Sections 13(a) or 
15(d) of the Exchange Act? 
If yes, go to #2; if no, go to #4. 

2. Does the issuer manufacture or contract to manufacture products?
If yes, go to #3; if no, go to #4. 

3. Are conflict minerals necessary to the functionality or production 
of the product manufactured or contracted to manufactured? 
If yes, go to #5; if no, go to #4. 

4. Rule does not apply: End. 

5. Were the conflict minerals outside the supply chain prior to 
January 31, 2013? 
Yes: go to #4. 
No, if potentially scrap or recycled, go to #6; 
No, if newly-mined, go to #7. 

6. Based on the RCOI, does the issuer know or reasonably believe that 
the conflict minerals come from scrap or recycled? 
If yes, go to #8; if no, go to #7. 

7. Based on a reasonable country of origin inquiry (RCOI), does the 
issuer know or have reason to believe that the conflict minerals may 
have originated in the DRC or an adjoining country (the covered 
countries)? 
If yes, go to #8; if no, go to #9. 

8. File a Form SD that discloses the issuer’s determination and 
briefly describes the RCOI and the results of the inquiry: End. 

9. Exercise due diligence on the source and chain of custody of its 
conflict minerals following a nationally or internationally recognized 
due diligence framework, if such framework is available for a specific 
conflict mineral. In exercising this due diligence does the issuer 
determine the conflict minerals are not from the covered countries or 
are from scrap or recycled? 
If yes, go to #10; if no, go to #11. 

10. File a Form SD that discloses the issuer’s determination and 
briefly describes the RCOI and due diligence measures taken and the 
results thereof: End. 

11. File a Form SD with a Conflict Minerals Report as an exhibit, 
which includes a description of the measures the issuer has taken to 
exercise due diligence. In exercising the due diligence, was the 
issuer able to determine whether the conflict minerals financed or 
benefited armed groups? 
If yes, go to #14; if no, go to #12. 

12. Is it less than two years after effectiveness of the rule (four 
years for Smaller Reporting Companies)? 
If yes, go to #14; if no, go to #13. 

13. The Conflict Minerals Report must also include a description of 
products that are “DRC Conflict Undeterminable” and the steps taken or 
that will be taken, if any, since the end of the period covered in the 
last Conflict Minerals Report to mitigate the risk that the necessary 
conflict minerals benefit armed groups, including any steps to improve 
due diligence. No audit is required: End. 

14. The Conflict Minerals Report must also include an independent 
private sector audit report, which expresses an opinion or conclusion 
as to whether the design of the issuer’s due diligence measures is in 
conformity with the criteria set forth in the due diligence framework 
and whether the description of the issuer’s due diligence measures is 
consistent with the process undertaken by the issuer. 

Also, include a description of the products that have not been found 
to be DRC Conflict Free, the facilities used to process the necessary 
conflict minerals in those products, the country of origin of the 
minerals and the efforts to determine the mine or location of origin 
of those minerals with the greatest possible specificity: End. 

[End of figure] 

Note: SEC indicated that the flowchart is intended to be used as a 
guide and that issuers should refer to the text in the rule for a more 
comprehensive description of the rule's requirements. Further, SEC 
indicated that, as a result of the appeals court decision, SEC's stay 
order, and SEC staff's guidance, some of the steps outlined in the 
flowchart have been modified pending further action by SEC or a court. 

Source: SEC. GAO-14-575. 

[End of figure] 

[End of section] 

Appendix IV: Sample Data from the ITRI Supply Chain Initiative: 

The ITRI Supply Chain Initiative (iTSCi) publishes qualitative and 
quantitative information on its projects in the DRC and Rwanda on its 
website. The information includes production data for minerals that 
have been mined and traded employing the iTSCi traceability system, 
audits of iTSCi member companies, and assessments of the political and 
security situation in various sites in the DRC and Rwanda. The mineral 
production and export data include minerals mined under the auspices 
of other stakeholder-led initiatives in the region. Almost all of the 
initiatives employ the iTSCi traceability system to track the mining 
and trading of minerals along the supply chain.[Footnote 61] 

One limitation of the data is that the production data-disaggregated 
by mineral and mine-are proprietary to iSTCi members. Therefore, it is 
not possible to quantify the total quantity or value of any of the 
minerals separately.[Footnote 62] 

Tables 2-7 provide iTSCi production in metric tons and mineral sales 
in thousands of U.S. dollars for tin, tungsten, and tantalum coming 
from several provinces in the DRC, including Maniema, South Kivu, and 
Katanga. 

Table 2: Production of Minerals from Maniema Covered by iTSCi for Q1 
and Q2 of 2013, in Metric Tons: 

2013: Q1; 
Tin: 17; 
Tin/Tantalum[A]: [Empty]; 
Tin/Tungsten[A]: 11; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 1. 

2013: Q2; 
Tin: 225; 
Tin/Tantalum[A]: 1; 
Tin/Tungsten[A]: 17; 
Tantalum/Tungsten[A]: 1; 
Tungsten: [Empty]. 

2013: Total; 
Tin: 242; 
Tin/Tantalum[A]: 1; 
Tin/Tungsten[A]: 28; 
Tantalum/Tungsten[A]: 1; 
Tungsten: 1. 

Source: GAO based on iTSCi data. GAO-14-575. 

Note: Empty cells indicate no recorded production. 

[A] iTSCi data include traced material that are reported as 
combinations of more than one mineral. 

[End of table] 

Table 3: Sales of Minerals from Maniema Covered by iTSCi for Q1 and Q2 
of 2013, in Thousands of U.S. Dollars: 

2013: Q1; 
Tin: $87; 
Tin/Tantalum[A]: [Empty]; 
Tin/Tungsten[A]: $46; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $1. 

2013: Q2; 
Tin: $1,163; 
Tin/Tantalum[A]: $5; 
Tin/Tungsten[A]: $84; 
Tantalum/Tungsten[A]: $3; 
Tungsten: [Empty]. 

2013: Total; 
Tin: $1,250; 
Tin/Tantalum[A]: $5; 
Tin/Tungsten[A]: $130; 
Tantalum/Tungsten[A]: $3; 
Tungsten: $1. 

Source: GAO based on iTSCi data. GAO-14-575. 

Note: Empty cells indicate no recorded sales. 

[A] iTSCi data include traced material that are reported as 
combinations of more than one mineral. 

[End of table] 

Table 4: Production of Minerals from South Kivu Covered by iTSCi for 
Q4 of 2012 through Q2 of 2013, in Metric Tons: 

Year/Quarter: 2012/Q4; 
Tin: 181; 
Tin/Tantalum[A]: [Empty]. 

Year/Quarter: 2013/Q1; 
Tin: 200; 
Tin/Tantalum[A]: [Empty]. 

Year/Quarter: 2013/Q2; 
Tin: 80; 
Tin/Tantalum[A]: 1. 

Year/Quarter: Total; 
Tin: 460; 
Tin/Tantalum[A]: 1. 

Source: GAO based on iTSCi data. GAO-14-575. 

Note: Empty cells indicate no recorded production. Totals may not add 
due to rounding. 

[A] iTSCi data include traced material that are reported as 
combinations of more than one mineral. 

[End of table] 

Table 5: Sales of Minerals from South Kivu Covered by iTSCi for Q4 of 
2012 through Q2 of 2013, in Thousands of U.S. Dollars: 

Year/Quarter: 2012/Q4; 
Tin: $760; 
Tin/Tantalum[A]: [Empty]. 

Year/Quarter: 2013/Q1; 
Tin: $800; 
Tin/Tantalum[A]: [Empty]. 

Year/Quarter: 2013/Q2; 
Tin: $286; 
Tin/Tantalum[A]: $3. 

Year/Quarter: Total; 
Tin: $1,847; 
Tin/Tantalum[A]: $3. 

Source: GAO based on iTSCi data. GAO-14-575. 

Note: Empty cells indicate no recorded sales. Totals may not add due 
to rounding. 

[A] iTSCi data include traced material that are reported as 
combinations of more than one mineral. 

[End of table] 

Table 6: Production of Minerals from Katanga Covered by iTSCi for Q2 
of 2011 through Q2 of 2013, in Metric Tons: 

Year/Quarter: 2011/Q2; 
Tin: 796; 
Tin/Tantalum[A]: 193; 
Tin/Tungsten[A]: 2; 
Tantalum: 54; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 3. 

Year/Quarter: 2011/Q3; 
Tin: 1,436; 
Tin/Tantalum[A]: 234; 
Tin/Tungsten[A]: 2; 
Tantalum: 51; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 16. 

Year/Quarter: 2011/Q4; 
Tin: 779; 
Tin/Tantalum[A]: 121; 
Tin/Tungsten[A]: 2; 
Tantalum: 128; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 26. 

Year/Quarter: 2012/Q1; 
Tin: 753; 
Tin/Tantalum[A]: 252; 
Tin/Tungsten[A]: 15; 
Tantalum: 114; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 12. 

Year/Quarter: 2012/Q2; 
Tin: 651; 
Tin/Tantalum[A]: 275; 
Tin/Tungsten[A]: 40; 
Tantalum: 60; 
Tantalum/Tungsten[A]: 2; 
Tungsten: 15. 

Year/Quarter: 2012/Q3; 
Tin: 671; 
Tin/Tantalum[A]: 258; 
Tin/Tungsten[A]: 18; 
Tantalum: 64; 
Tantalum/Tungsten[A]: 2; 
Tungsten: 40. 

Year/Quarter: 2012/Q4; 
Tin: 497; 
Tin/Tantalum[A]: 188; 
Tin/Tungsten[A]: 7; 
Tantalum: 45; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 29. 

Year/Quarter: 2013/Q1; 
Tin: 340; 
Tin/Tantalum[A]: 211; 
Tin/Tungsten[A]: 7; 
Tantalum: 34; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 9. 

Year/Quarter: 2013/Q2; 
Tin: 648; 
Tin/Tantalum[A]: 441; 
Tin/Tungsten[A]: 2; 
Tantalum: 40; 
Tantalum/Tungsten[A]: 0.4; 
Tungsten: 6. 

Year/Quarter: Total; 
Tin: 6,572; 
Tin/Tantalum[A]: 2,172; 
Tin/Tungsten[A]: 97; 
Tantalum: 588; 
Tantalum/Tungsten[A]: 3; 
Tungsten: 155. 

Source: GAO based on iTSCi data. GAO-14-575. 

Note: Empty cells indicate no recorded production. Totals may not add 
due to rounding. 

[A] iTSCi data include traced material that are reported as 
combinations of more than one mineral. 

[End of table] 

Table 7: Sales of Minerals from Katanga Covered by iTSCi for Q2 of 
2011 through Q2 of 2013, in Thousands of U.S. Dollars: 

Year/Quarter: 2011/Q2; 
Tin: $5,166; 
Tin/Tantalum[A]: $1,290; 
Tin/Tungsten[A]: $14; 
Tantalum: $1,548; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $21. 

Year/Quarter: 2011/Q3; 
Tin: $9,839; 
Tin/Tantalum[A]: $1,746; 
Tin/Tungsten[A]: $18; 
Tantalum: $1,733; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $122. 

Year/Quarter: 2011/Q4; 
Tin: $4,072; 
Tin/Tantalum[A]: $718; 
Tin/Tungsten[A]: $40; 
Tantalum: $4,448; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $152. 

Year/Quarter: 2012/Q1; 
Tin: $4,224; 
Tin/Tantalum[A]: $1,783; 
Tin/Tungsten[A]: $67; 
Tantalum: $3,758; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $70. 

Year/Quarter: 2012/Q2; 
Tin: $3,701; 
Tin/Tantalum[A]: $1,811; 
Tin/Tungsten[A]: $193; 
Tantalum: $2,012; 
Tantalum/Tungsten[A]: $7; 
Tungsten: $97. 

Year/Quarter: 2012/Q3; 
Tin: $3,352; 
Tin/Tantalum[A]: $1,720; 
Tin/Tungsten[A]: $172; 
Tantalum: $2,114; 
Tantalum/Tungsten[A]: $5; 
Tungsten: $181. 

Year/Quarter: 2012/Q4; 
Tin: $2,906; 
Tin/Tantalum[A]: $1,268; 
Tin/Tungsten[A]: $106; 
Tantalum: $1,571; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $105. 

Year/Quarter: 2013/Q1; 
Tin: $2,112; 
Tin/Tantalum[A]: $1,449; 
Tin/Tungsten[A]: $38; 
Tantalum: $1,092; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $74. 

Year/Quarter: 2013/Q2; 
Tin: $3,744; 
Tin/Tantalum[A]: $3,583; 
Tin/Tungsten[A]: $11; 
Tantalum: $1,502; 
Tantalum/Tungsten[A]: $2; 
Tungsten: $19. 

Year/Quarter: Total; 
Tin: $39,117; 
Tin/Tantalum[A]: $15,367; 
Tin/Tungsten[A]: $659; 
Tantalum: $19,778; 
Tantalum/Tungsten[A]: $15; 
Tungsten: $840. 

Source: GAO based on iTSCi data. GAO-14-575. 

Note: Empty cells indicate no recorded sales. Totals may not add due 
to rounding. 

[A] iTSCi data include traced material that are reported as 
combinations of more than one mineral. 

[End of table] 

Tables 8 and 9 provide iTSCi production in tons and mineral sales in 
thousands of U.S. dollars for tin, tungsten and tantalum in Rwanda. 

Table 8: Production of Minerals from Rwanda Covered by iTSCi for Q2 of 
2011 through Q2 of 2013, in Metric Tons: 

Year/Quarter: 2011/Q2; 
Tin: 1,393; 
Tin/Tantalum[A]: 442; 
Tin/Tungsten[A]: 3; 
Tin/Tantalum/Tungsten[A]: 3; 
Tantalum: 56; 
Tantalum/Tungsten[A]: 1; 
Tungsten: 353. 

Year/Quarter: 2011/Q3; 
Tin: 1,318; 
Tin/Tantalum[A]: 406; 
Tin/Tungsten[A]: 1; 
Tin/Tantalum/Tungsten[A]: 4; 
Tantalum: 56; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 438. 

Year/Quarter: 2011/Q4; 
Tin: 1,387; 
Tin/Tantalum[A]: 381; 
Tin/Tungsten[A]: 14; 
Tin/Tantalum/Tungsten[A]: 1; 
Tantalum: 41; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 528. 

Year/Quarter: 2012/Q1; 
Tin: 825; 
Tin/Tantalum[A]: 316; 
Tin/Tungsten[A]: 8; 
Tin/Tantalum/Tungsten[A]: 3; 
Tantalum: 102; 
Tantalum/Tungsten[A]: 3; 
Tungsten: 575. 

Year/Quarter: 2012/Q2; 
Tin: 671; 
Tin/Tantalum[A]: 397; 
Tin/Tungsten[A]: 5; 
Tin/Tantalum/Tungsten[A]: 16; 
Tantalum: 108; 
Tantalum/Tungsten[A]: 1; 
Tungsten: 605. 

Year/Quarter: 2012/Q3; 
Tin: 780; 
Tin/Tantalum[A]: 509; 
Tin/Tungsten[A]: 4; 
Tin/Tantalum/Tungsten[A]: 26; 
Tantalum: 162; 
Tantalum/Tungsten[A]: 1; 
Tungsten: 582. 

Year/Quarter: 2012/Q4; 
Tin: 842; 
Tin/Tantalum[A]: 489; 
Tin/Tungsten[A]: 2; 
Tin/Tantalum/Tungsten[A]: 24; 
Tantalum: 165; 
Tantalum/Tungsten[A]: 2; 
Tungsten: 454. 

Year/Quarter: 2013/Q1; 
Tin: 915; 
Tin/Tantalum[A]: 678; 
Tin/Tungsten[A]: 1; 
Tin/Tantalum/Tungsten[A]: 3; 
Tantalum: 178; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 538. 

Year/Quarter: 2013/Q2; 
Tin: 827; 
Tin/Tantalum[A]: 799; 
Tin/Tungsten[A]: 1; 
Tin/Tantalum/Tungsten[A]: [Empty]; 
Tantalum: 248; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: 486. 

Year/Quarter: Total; 
Tin: 8,958; 
Tin/Tantalum[A]: 4,417; 
Tin/Tungsten[A]: 39; 
Tin/Tantalum/Tungsten[A]: 79; 
Tantalum: 1,115; 
Tantalum/Tungsten[A]: 8; 
Tungsten: 4,560. 

Source: GAO based on iTSCi data. GAO-14-575. 

Note: Empty cells indicate no recorded production. Totals may not add 
due to rounding. 

[A] iTSCi data include traced material that are reported as 
combinations of more than one mineral. 

[End of table] 

Table 9: Sales of Minerals from Rwanda Covered by iTSCi for Q2 of 2011 
through Q2 of 2013, in Thousands of U.S. Dollars: 

Year/Quarter: 2011/Q2; 
Tin: $11,481; 
Tin/Tantalum[A]: $6,217; 
Tin/Tungsten[A]: $32; 
Tin/Tantalum/Tungsten[A]: $25; 
Tantalum: $1,095; 
Tantalum/Tungsten[A]: $8; 
Tungsten: $1,988. 

Year/Quarter: 2011/Q3; 
Tin: $9,533; 
Tin/Tantalum[A]: $4,778; 
Tin/Tungsten[A]: $16; 
Tin/Tantalum/Tungsten[A]: $26; 
Tantalum: $972; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $2,935. 

Year/Quarter: 2011/Q4; 
Tin: $9,333; 
Tin/Tantalum[A]: $4,423; 
Tin/Tungsten[A]: $154; 
Tin/Tantalum/Tungsten[A]: $10; 
Tantalum: $720; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $3,608. 

Year/Quarter: 2012/Q1; 
Tin: $4,874; 
Tin/Tantalum[A]: $4,383; 
Tin/Tungsten[A]: $92; 
Tin/Tantalum/Tungsten[A]: $26; 
Tantalum: $2,068; 
Tantalum/Tungsten[A]: $17; 
Tungsten: $4,007. 

Year/Quarter: 2012/Q2; 
Tin: $3,369; 
Tin/Tantalum[A]: $4,980; 
Tin/Tungsten[A]: $31; 
Tin/Tantalum/Tungsten[A]: $98; 
Tantalum: $2,098; 
Tantalum/Tungsten[A]: $15; 
Tungsten: $4,691. 

Year/Quarter: 2012/Q3; 
Tin: $4,273; 
Tin/Tantalum[A]: $6,394; 
Tin/Tungsten[A]: $27; 
Tin/Tantalum/Tungsten[A]: $176; 
Tantalum: $3,473; 
Tantalum/Tungsten[A]: $12; 
Tungsten: $4,891. 

Year/Quarter: 2012/Q4; 
Tin: $6,026; 
Tin/Tantalum[A]: $8,008; 
Tin/Tungsten[A]: $26; 
Tin/Tantalum/Tungsten[A]: $263; 
Tantalum: $4,148; 
Tantalum/Tungsten[A]: $35; 
Tungsten: $4,235. 

Year/Quarter: 2013/Q1; 
Tin: $6,982; 
Tin/Tantalum[A]: $11,031; 
Tin/Tungsten[A]: $19; 
Tin/Tantalum/Tungsten[A]: $59; 
Tantalum: $5,654; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $6,678. 

Year/Quarter: 2013/Q2; 
Tin: $5,988; 
Tin/Tantalum[A]: $14,857; 
Tin/Tungsten[A]: $24; 
Tin/Tantalum/Tungsten[A]: [Empty]; 
Tantalum: $8,331; 
Tantalum/Tungsten[A]: [Empty]; 
Tungsten: $4,605. 

Year/Quarter: Total; 
Tin: $61,859; 
Tin/Tantalum[A]: $65,070; 
Tin/Tungsten[A]: $421; 
Tin/Tantalum/Tungsten[A]: $683; 
Tantalum: $28,560; 
Tantalum/Tungsten[A]: $87; 
Tungsten: $37,637. 

Source: GAO based on iTSCi data. GAO-14-575. 

Note: Empty cells indicate no recorded sales. Totals may not add due 
to rounding. 

[A] iTSCi data include traced material that are reported as 
combinations of more than one mineral. 

[End of table] 

[End of section] 

Appendix V: Conflict Mineral Production and Export Data as Reported by 
the DRC and Rwandan Governments: 

The DRC Ministry of Mines published data on the volume of production 
and exports for tin, tantalum, tungsten, and gold for 2003-2012 (see 
tables 10-13).[Footnote 63] 

Table 10: Total Volume of Tin Production and Export from DRC for 2003-
2012, in Metric Tons: 

2003; 
Production: 2,986; 
Export: 2,986. 

2004; 
Production: 2,317; 
Export: 2,945. 

2005; 
Production: 5,171; 
Export: 5,971. 

2006; 
Production: 5,528; 
Export: 2,388. 

2007; 
Production: 16,050; 
Export: 14,694. 

2008; 
Production: 20,013; 
Export: 19,189. 

2009; 
Production: 16,584; 
Export: 15,512. 

2010; 
Production: 11,943; 
Export: 13,415. 

2011; 
Production: 8,921; 
Export: 9,267. 

2012; 
Production: 7,189; 
Export: 8,018. 

Total; 
Production: 96,702; 
Export: 94,385. 

Source: GAO based on DRC Ministry of Mines. GAO-14-575. 

[End of table] 

Table 11: Total Volume of Tantalum Production and Export from DRC for 
2003-2012, in Metric Tons: 

2003; 
Production: 47; 
Export: 47. 

2004; 
Production: 78; 
Export: 32. 

2005; 
Production: 184; 
Export: 185. 

2006; 
Production: 31; 
Export: 24. 

2007; 
Production: 393; 
Export: 393. 

2008; 
Production: 530; 
Export: 531. 

2009; 
Production: 509; 
Export: 464. 

2010; 
Production: 492; 
Export: 440. 

2011; 
Production: 2,199; 
Export: 536. 

2012; 
Production: 574; 
Export: 586. 

Total; 
Production: 5,037; 
Export: 3,238. 

Source: GAO based on DRC Ministry of Mines. GAO-14-575 

[End of table] 

Table 12: Total Volume of Tungsten Production and Export from DRC for 
2003-2012, in Metric Tons: 

2003; 
Production: No data; 
Export: 100. 

2004; 
Production: 272; 
Export: 190. 

2005; 
Production: 405; 
Export: 311. 

2006; 
Production: 1,001; 
Export: 471. 

2007; 
Production: 1,265; 
Export: 1,194. 

2008; 
Production: 621; 
Export: 725. 

2009; 
Production: 458; 
Export: 365. 

2010; 
Production: 44; 
Export: 45. 

2011; 
Production: 84; 
Export: 87. 

2012; 
Production: 197; 
Export: 71. 

Total; 
Production: 4,347; 
Export: 3,559. 

Source: GAO based on DRC Ministry of Mines. GAO-14-575. 

[End of table] 

Table 13: Total Volume of Gold Production and Export from DRC for 2003-
2012, in Metric Tons: 

2003; 
Production: No data; 
Export: No data. 

2004; 
Production: 0.7; 
Export: 0.0. 

2005; 
Production: 0.6; 
Export: 0.6. 

2006; 
Production: 0.3; 
Export: 0.1. 

2007; 
Production: 0.1; 
Export: 0.1. 

2008; 
Production: 0.1; 
Export: 0.1. 

2009; 
Production: 0.2; 
Export: 0.2. 

2010; 
Production: 0.2; 
Export: 0.2. 

2011; 
Production: 0.3; 
Export: 0.2. 

2012; 
Production: 2.8; 
Export: 2.4. 

Total; 
Production: 5.3; 
Export: 3.9. 

Source: GAO based on DRC Ministry of Mines. GAO-14-575. 

[End of table] 

The Rwanda Natural Resources Authority published data on the volume 
and value of tin, tantalum and tungsten exported from Rwanda from 
January to August of 2013 (see tables 14 and 15).[Footnote 64] 

Table 14: Total Volume of Tin, Tantalum, and Tungsten Exports from 
Rwanda January-August 2013, in Metric Tons: 

January; 
Tin: 421; 
Tantalum: 84; 
Tungsten: 184. 

February; 
Tin: 224; 
Tantalum: 48; 
Tungsten: 130. 

March; 
Tin: 475; 
Tantalum: 284; 
Tungsten: 185. 

April; 
Tin: 510; 
Tantalum: 251; 
Tungsten: 230. 

May; 
Tin: 458; 
Tantalum: 273; 
Tungsten: 157. 

June; 
Tin: 267; 
Tantalum: 212; 
Tungsten: 177. 

July; 
Tin: 396; 
Tantalum: 288; 
Tungsten: 151. 

August; 
Tin: 407; 
Tantalum: 245; 
Tungsten: 164. 

Total; 
Tin: 3,158; 
Tantalum: 1,686; 
Tungsten: 1,378. 

Source: GAO based on Rwanda Natural Resources Authority. GAO-14-575. 

Note: Totals may not add due to rounding. 

[End of table] 

Table 15: Total Value of Tin, Tantalum, and Tungsten Exports from 
Rwanda January-August 2013, in Thousands of U.S. Dollars: 

January; 
Tin: $5,386; 
Tantalum: $4,953; 
Tungsten: $2,178. 

February; 
Tin: $2,803; 
Tantalum: $3,012; 
Tungsten: $1,564. 

March; 
Tin: $8,314; 
Tantalum: $16,379; 
Tungsten: $2,118. 

April; 
Tin: $6,352; 
Tantalum: $15,736; 
Tungsten: $3,915. 

May; 
Tin: $5,365; 
Tantalum: $16,583; 
Tungsten: $2,075. 

June; 
Tin: $3,206; 
Tantalum: $12,373; 
Tungsten: $2,559. 

July; 
Tin: $4,297; 
Tantalum: $17,822; 
Tungsten: $2,103. 

August; 
Tin: $4,509; 
Tantalum: $15,144; 
Tungsten: $2,277. 

Total; 
Tin: $40,233; 
Tantalum: $102,002; 
Tungsten: $18,789. 

Source: GAO based on Rwanda Natural Resources Authority. GAO-14-575. 

Note: Totals may not add due to rounding. 

[End of table] 

[End of section] 

Appendix VI: Conflict Minerals Data from the International Trade 
Centre Data on Global Conflict Mineral Imports: 

The International Trade Centre (ITC), a joint agency of the World 
Trade Organization and the United Nations (UN) compiles a Trade Map 
with data including the global exports in tons and export value of 
tin, tantalum, tungsten and gold from the DRC and adjoining countries, 
as available for fiscal years 2009-2013 (see tables 16-31 for ITC data 
as of June 2014).[Footnote 65] The ITC calculated these data using the 
UN Commodity Trade Statistics Database, which compiles trade data from 
UN member countries. 

These data do not provide a comprehensive depiction of the flow of 
conflict minerals exported from the DRC and adjoining countries; 
rather, they are an estimate based on imports data from reporting 
partner countries. Furthermore, these data may include imports of 
conflict minerals that have financed armed groups.[Footnote 66] 

In many instances, there are no data listed for a particular mineral 
or year. There were no data for import volume or value of conflict 
minerals in the ITC database for the Republic of the Congo (Congo-
Brazzaville) or South Sudan. 

Table 16: ITC Estimates of Exports of Conflict Minerals from the 
Democratic Republic of the Congo for Fiscal Years 2009-2013, in Metric 
Tons: 

FY 2009; 
Tin: 160[A]; 
Tantalum[B]: 121[A]; 
Tungsten: 471[A]; 
Gold: No quantity[A]. 

FY 2010; 
Tin: 2,589[A]; 
Tantalum[B]: 252[A]; 
Tungsten: 87[A]; 
Gold: 0 [A]. 

FY 2011; 
Tin: 510[A]; 
Tantalum[B]: 101[A]; 
Tungsten: 10[A]; 
Gold: 0 [A]. 

FY 2012; 
Tin: 1,670[A]; 
Tantalum[B]: 326[A]; 
Tungsten: [Empty]; 
Gold: 0 [A]. 

FY 2013; 
Tin: 2,621[A]; 
Tantalum[B]: 329[A]; 
Tungsten: 95[A]; 
Gold: 0 [A]. 

Total; 
Tin: 7,550; 
Tantalum[B]: 1,129; 
Tungsten: 663; 
Gold: 0[A]. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. "No quantity" means that the country under 
review has reported a value but no quantity for the product and 
partner under review. Empty cells indicate that no partner country has 
reported importation of that mineral from that country. 

[A] According to the ITC, these estimates of exports have been 
reconstructed on the basis of data reported by importing partner 
countries, known as mirror statistics. The ITC states that mirror 
statistics are a "second-best solution" when no data exist but are 
subject to limitations, including the omission of non-reporting 
countries, particularly in Africa. 

[B] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 17: ITC Estimates of Export Value of Conflict Minerals from the 
DRC for F Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

FY 2009; 
Tin: $1,061[A]; 
Tantalum[B]: $2,575[A]; 
Tungsten: $4,357[A]; 
Gold: $1,251[A]. 

FY 2010; 
Tin: $23,045[A]; 
Tantalum[B]: $5,161[A]; 
Tungsten: $806a; 
Gold: $1,140[A]. 

FY 2011; 
Tin: $8,786[A]; 
Tantalum[B]: $9,131[A]; 
Tungsten: $263[A]; 
Gold: $4,426[A]. 

FY 2012; 
Tin: $17,719[A]; 
Tantalum[B]: $24,006[A]; 
Tungsten: [Empty]; 
Gold: $1,394[A]. 

FY 2013; 
Tin: $32,628[A]; 
Tantalum[B]: $22,142[A]; 
Tungsten: $1,339[A]; 
Gold: $2,729[A]. 

Total; 
Tin: $83,239; 
Tantalum[B]: $63,015; 
Tungsten: $6,765; 
Gold: $10,940. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, empty cells indicate that no partner 
country has reported importation of that mineral from that country. 

[A] According to the ITC, these estimates of exports have been 
reconstructed on the basis of data reported by importing partner 
countries, known as mirror statistics. The ITC states that mirror 
statistics are a "second-best solution" when no data exist, but are 
subject to limitations, including the omission of non-reporting 
countries, particularly in Africa. 

[B] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 18: ITC Estimates of Exports of Conflict Minerals from Angola 
for Fiscal Years 2009-2012, in Metric Tons: 

FY 2009; 
Tin: [Empty]; 
Tantalum[B]: [Empty]; 
Tungsten: [Empty]; 
Gold: [Empty]. 

FY 2010; 
Tin: [Empty]; 
Tantalum[B]: [Empty]; 
Tungsten: [Empty]; 
Gold: [Empty]. 

FY 2011; 
Tin: [Empty]; 
Tantalum[B]: [Empty]; 
Tungsten: No quantity[A]; 
Gold: 0. 

FY 2012; 
Tin: [Empty]; 
Tantalum[B]: 19[A]; 
Tungsten: [Empty]; 
Gold: [Empty]. 

FY 2013; 
Tin: No quantity[A]; 
Tantalum[B]: 28[A]; 
Tungsten: [Empty]; 
Gold: [Empty]. 

Total; 
Tin: [Empty]; 
Tantalum[B]: 47; 
Tungsten: [Empty]; 
Gold: 0. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. "No quantity" means that the country under 
review has reported a value but no quantity for the product and 
partner under review. Empty cells indicate that no partner country has 
reported importation of that mineral from that country. 

[A] According to the ITC, these estimates of exports have been 
reconstructed on the basis of data reported by importing partner 
countries, known as mirror statistics. The ITC states that mirror 
statistics are a "second-best solution" when no data exist ,but are 
subject to limitations, including the omission of non-reporting 
countries, particularly in Africa. 

[B] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 19: ITC Estimates of Export Value of Conflict Minerals from 
Angola for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

FY 2009; 
Tin: [Empty]; 
Tantalum[B]: [Empty]; 
Tungsten: [Empty]; 
Gold: [Empty]. 

FY 2010; 
Tin: [Empty]; 
Tantalum[B]: [Empty]; 
Tungsten: [Empty]; 
Gold: [Empty]. 

FY 2011; 
Tin: [Empty]; 
Tantalum[B]: [Empty]; 
Tungsten: $0[A]; 
Gold: $90[A]. 

FY 2012; 
Tin: [Empty]; 
Tantalum[B]: $31[A]; 
Tungsten: [Empty]; 
Gold: [Empty]. 

FY 2013; 
Tin: $0[A]; 
Tantalum[B]: $7; 
Tungsten: [Empty]; 
Gold: [Empty]. 

Total; 
Tin: $0; 
Tantalum[B]: $38; 
Tungsten: $0; 
Gold: $90. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. Empty cells indicate that no partner country 
has reported importation of that mineral from that country. 

[A] According to the ITC, these estimates of exports have been 
reconstructed on the basis of data reported by importing partner 
countries, known as mirror statistics. The ITC states that mirror 
statistics are a "second-best solution" when no data exist, but are 
subject to limitations, including the omission of non-reporting 
countries, particularly in Africa. 

[B] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 20: ITC Estimates of Exports of Conflict Minerals from Burundi 
for Fiscal Years 2009-2012, in Metric Tons: 

FY2009; 
Tin: 26; 
Tantalum[A]: 0; 
Tungsten: 264; 
Gold: 1. 

FY2010; 
Tin: 32; 
Tantalum[A]: 0; 
Tungsten: 503; 
Gold: 0. 

FY2011; 
Tin: 0; 
Tantalum[A]: 17; 
Tungsten: 330; 
Gold: 1. 

FY2012; 
Tin: 0; 
Tantalum[A]: 0; 
Tungsten: 32; 
Gold: 2. 

FY2013; 
Tin: No quantity; 
Tantalum[A]: 76; 
Tungsten: 148; 
Gold: 3. 

Total; 
Tin: 58; 
Tantalum[A]: 93; 
Tungsten: 1,277; 
Gold: 7. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. "No quantity" means that the country under 
review has reported a value but no quantity for the product and 
partner under review. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 21: ITC Estimates of Export Value of Conflict Minerals from 
Burundi for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

FY 2009; 
Tin: $175; 
Tantalum[A]: $0; 
Tungsten: $1,547; 
Gold: $28,979. 

FY 2010; 
Tin: $297; 
Tantalum[A]: $0; 
Tungsten: $2,951; 
Gold: $13,003. 

FY 2011; 
Tin: $15; 
Tantalum[A]: $20; 
Tungsten: $4,607; 
Gold: $59,047. 

FY 2012; 
Tin: $0; 
Tantalum[A]: $0; 
Tungsten: $226; 
Gold: $105,196. 

FY 2013; 
Tin: $0; 
Tantalum[A]: $2,753; 
Tungsten: $1,776; 
Gold: $121,470. 

Total; 
Tin: $487; 
Tantalum[A]: $2,773; 
Tungsten: $11,107; 
Gold: $327,695. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 22: ITC Estimates of Exports of Conflict Minerals from Central 
African Republic for Fiscal Years 2009-2012, in Metric Tons: 

FY 2009; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: 24. 

FY 2010; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: 49. 

FY 2011; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: 21. 

FY 2012; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: 6. 

FY 2013; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: 691. 

Total; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: 791. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, empty cells indicate that no partner 
country has reported importation of that mineral from that country. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 23: ITC Estimates of Export Value of Conflict Minerals from 
Central African Republic for Fiscal Years 2009-2013, in Thousands of 
U.S. Dollars: 

FY 2009; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: $473. 

FY 2010; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: $1,277. 

FY 2011; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: $2,509. 

FY 2012; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: $1,367. 

FY 2013; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: $318. 

Total; 
Tin: [Empty]; 
Tantalum[A]: [Empty]; 
Tungsten: [Empty]; 
Gold: $5,944. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, empty cells indicate that no partner 
country has reported importation of that mineral from that country. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 24: ITC Estimates of Exports of Conflict Minerals from Rwanda 
for Fiscal Years 2009-2012, in Metric Tons: 

FY 2009; 
Tin: 5,224; 
Tantalum[A]: 958; 
Tungsten: 945; 
Gold: 0. 

FY 2010; 
Tin: 6,477; 
Tantalum[A]: 827; 
Tungsten: 879; 
Gold: 0. 

FY 2011; 
Tin: 7,314; 
Tantalum[A]: 915; 
Tungsten: 784; 
Gold: 0. 

FY 2012; 
Tin: 4,658; 
Tantalum[A]: 1,139; 
Tungsten: 1,372; 
Gold: 0. 

FY 2013; 
Tin: 4,820; 
Tantalum[A]: 2,466; 
Tungsten: 2,119; 
Gold: 0. 

Total; 
Tin: 28,493; 
Tantalum[A]: 6,305; 
Tungsten: 6,099; 
Gold: 0. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 25: ITC Estimates of Export Value of Conflict Minerals from 
Rwanda for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

FY 2009; 
Tin: $34,235; 
Tantalum[A]: $18,082; 
Tungsten: $6,283; 
Gold: $856. 

FY 2010; 
Tin: $65,834; 
Tantalum[A]: $20,034; 
Tungsten: $7,254; 
Gold: $170. 

FY 2011; 
Tin: $101,921; 
Tantalum[A]: $39,000; 
Tungsten: $11,677; 
Gold: 0. 

FY 2012; 
Tin: $52,912; 
Tantalum[A]: $56,698; 
Tungsten: $21,354; 
Gold: 0. 

FY 2013; 
Tin: $57,957; 
Tantalum[A]: $134,575; 
Tungsten: $28,866; 
Gold: 0. 

Total; 
Tin: $312,859; 
Tantalum[A]: $268,389; 
Tungsten: $75,434; 
Gold: $1,026. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 26: ITC Estimates of Export of Conflict Minerals from Tanzania 
for Fiscal Years 2009-2012, in Metric Tons: 

FY2009; 
Tin: 0; 
Tantalum[A]: 0; 
Tungsten: 0; 
Gold: 402. 

FY2010; 
Tin: 1; 
Tantalum[A]: 0; 
Tungsten: 0; 
Gold: 325. 

FY2011; 
Tin: 66; 
Tantalum[A]: 160; 
Tungsten: 0; 
Gold: 43. 

FY2012; 
Tin: 71; 
Tantalum[A]: 112; 
Tungsten: 0; 
Gold: 319. 

FY2013; 
Tin: 57; 
Tantalum[A]: No quantity; 
Tungsten: No quantity; 
Gold: 140. 

Total; 
Tin: 195; 
Tantalum[A]: 272; 
Tungsten: 0; 
Gold: 1,229. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. "No quantity" means that the country under 
review has reported a value but no quantity for the product and 
partner under review. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 27: ITC Estimates of Export Value of Conflict Minerals from 
Tanzania for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

FY2009; 
Tin: $0; 
Tantalum[A]: $0; 
Tungsten: $0; 
Gold: $818,598. 

FY2010; 
Tin: $5; 
Tantalum[A]: $0; 
Tungsten: $0; 
Gold: $966,077. 

FY2011; 
Tin: $373; 
Tantalum[A]: $59; 
Tungsten: $0; 
Gold: $1,718,196. 

FY2012; 
Tin: $351; 
Tantalum[A]: $153; 
Tungsten: $0; 
Gold: $1,863,327. 

FY2013; 
Tin: $329; 
Tantalum[A]: $0; 
Tungsten: $0; 
Gold: $1,549,580. 

Total; 
Tin: $1,058; 
Tantalum[A]: $212; 
Tungsten: $0; 
Gold: $6,915,778. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 28: ITC Estimates of Exports of Conflict Minerals from Uganda 
for Fiscal Years 2009-2012, in Metric Tons: 

FY2009; 
Tin: 7; 
Tantalum[A]: No quantity; 
Tungsten: 0; 
Gold: 1. 

FY2010; 
Tin: No quantity; 
Tantalum[A]: No quantity; 
Tungsten: 0; 
Gold: 1. 

FY2011; 
Tin: 0; 
Tantalum[A]: No quantity; 
Tungsten: No quantity; 
Gold: 0. 

FY2012; 
Tin: No quantity; 
Tantalum[A]: No Quantity; 
Tungsten: 100; 
Gold: 0. 

FY2013; 
Tin: 12; 
Tantalum[A]: 8; 
Tungsten: 91; 
Gold: 0. 

Total; 
Tin: 19; 
Tantalum[A]: 8; 
Tungsten: 191; 
Gold: 2. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. "No quantity" means that the country under 
review has reported a value but no quantity for the product and 
partner under review. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 29: ITC Estimates of Export Value of Conflict Minerals from 
Uganda for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

FY2009; 
Tin: $2; 
Tantalum[A]: $0; 
Tungsten: $0; 
Gold: $13,100. 

FY2010; 
Tin: $0; 
Tantalum[A]: $0; 
Tungsten: $0; 
Gold: $30,072. 

FY2011; 
Tin: $1; 
Tantalum[A]: $0; 
Tungsten: $0; 
Gold: $6,795. 

FY2012; 
Tin: $0; 
Tantalum[A]: $0; 
Tungsten: $979; 
Gold: $9,163. 

FY2013; 
Tin: $128; 
Tantalum[A]: $22; 
Tungsten: $972; 
Gold: $3,128. 

Total; 
Tin: $131; 
Tantalum[A]: $22; 
Tungsten: $1,951; 
Gold: $62,258. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 30: ITC Estimates of Exports of Conflict Minerals from Zambia 
for Fiscal Years 2009-2012, in Metric Tons: 

FY2009; 
Tin: 27; 
Tantalum[A]: No quantity; 
Tungsten: 0; 
Gold: 695. 

FY2010; 
Tin: 0; 
Tantalum[A]: No quantity; 
Tungsten: 23; 
Gold: 555. 

FY2011; 
Tin: 28; 
Tantalum[A]: 0; 
Tungsten: 72; 
Gold: 2. 

FY2012; 
Tin: 0; 
Tantalum[A]: No quantity; 
Tungsten: 0; 
Gold: 1,492. 

FY2013; 
Tin: 6; 
Tantalum[A]: 0; 
Tungsten: 0; 
Gold: 4. 

Total; 
Tin: 61; 
Tantalum[A]: 0; 
Tungsten: 95; 
Gold: 2,748. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. "No quantity" means that the country under 
review has reported a value but no quantity for the product and 
partner under review. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

Table 31: ITC Estimates of Export Value of Conflict Minerals from 
Zambia for Fiscal Years 2009-2013, in Thousands of U.S. Dollars: 

FY2009; 
Tin: $77; 
Tantalum[A]: $0; 
Tungsten: $0; 
Gold: $19,004. 

FY2010; 
Tin: $1; 
Tantalum[A]: $0; 
Tungsten: $12; 
Gold: $46,411. 

FY2011; 
Tin: $50; 
Tantalum[A]: $0; 
Tungsten: $6; 
Gold: $81,040. 

FY2012; 
Tin: $0; 
Tantalum[A]: $0; 
Tungsten: $0; 
Gold: $140,744. 

FY2013; 
Tin: $4; 
Tantalum[A]: $0; 
Tungsten: $0; 
Gold: $164,079. 

Total; 
Tin: $132; 
Tantalum[A]: $0; 
Tungsten: $18; 
Gold: $451,278. 

Source: GAO analysis of Trade Map data. GAO-14-575. 

Note: According to the ITC, if there is no record in the export 
dataset for a specific mineral and a specific partner country, they 
consider that the country has not exported the mineral for that year 
and publish a zero value. 

[A] Export data for tantalum ores and concentrates also include 
exports of niobium and vanadium ores and concentrates. 

[End of table] 

[End of section] 

Appendix VII: Comments from the Department of Commerce: 

The Deputy Secretary of Commerce: 
Washington, D.C. 20230: 

June 13, 2014: 

Ms. Kimberley M. Gianopoulos: 
Acting Director, International Affairs and Trade: 
U.S. Government Accountability Office: 
441 G Street NW: 
Washington, DC 20548: 

Dear Ms. Gianopoulos: 

Thank you for providing the Department of Commerce (Commerce) with a 
copy of the U.S. Government Accountability Office (GAO) proposed 
report entitled Conflict Minerals: Stakeholder Options/or Responsible 
Sourcing Expanding, but More Information on Smelters Is Needed (GAO-14-
575) for our review and comment prior to issuance of the report. 

As we noted in our meetings with GAO staff both in January and May, 
the International Trade Administration (ITA) faced significant 
challenges in implementing Commerce's reporting requirements under 
Section 1502(d) of the Dodd-Frank Act. ITA is focused on a two-part
mission: (1) advancing Commerce's statutory mandate to foster, 
promote, and develop the foreign commerce of the United States; (2) 
creating prosperity by strengthening the international competitiveness 
of U.S. industry, promoting trade and investment, and ensuring fair 
trade and compliance with trade laws and agreements. 

As a result of the focus on its mission, at the time the Dodd-Frank 
Act was enacted, ITA did not have staff available or trained to carry 
out the conflict minerals reporting requirements specified therein. 
Instead, we were required to survey existing capabilities, divert 
resources from other initiatives, and train existing staff in order to 
implement those requirements. As we explained in our meetings with GAO 
staff, based on our meetings with the Department of the Interior's 
U.S. Geological Survey (USGS), we believe that USGS has ongoing program
activities, existing resources, and institutional expertise and 
capacity that would have allowed it to more readily meet the Dodd-
Frank Act requirement regarding reporting on a list of all known
conflict mineral processing facilities. 

Despite these obstacles, ITA staff has successfully completed its 
outreach plan and has collected information from a number of publicly 
available sources in order to develop the "listing of all known 
conflict mineral processing facilities worldwide," called for by the 
Dodd-Frank Act. We agree with GAO that developing a plan of action is 
the first step in developing such a list. In fact, on February 26, we 
provided a detailed action plan to GAO, setting forth exactly how ITA
intends to assemble this list, and also briefed GAO on this action 
plan during our two meetings. Implications to the contrary in GAO's 
draft report are inaccurate. 

With respect to GAO's recommendation 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," we plan to
implement GAO's recommendation by submitting a listing of all known 
conflict mineral processing facilities worldwide to Congress by 
September I. 

Thank you again for the opportunity to provide review and comment on 
the draft report. 

Sincerely, 

Signed by: 

Bruce Andrews: 
Acting Deputy Secretary of Commerce: 

[End of section] 

Appendix VIII: GAO Contacts and Staff Acknowledgments: 

GAO Contact: 

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

Staff Acknowledgments: 

In addition to the individual named above, Godwin Agbara (Assistant 
Director), Russ Burnett, Etana Finkler, Justin Fisher, Julia Jebo 
Grant, Ernie Jackson, Jill Lacey, Reid Lowe, Andrea Riba Miller, and 
John O'Trakoun made key contributions to this report. 

[End of section] 

Footnotes: 

[1] GAO, The Democratic Republic of the Congo: U.S. Agencies Should 
Take Further Actions to Contribute to the Effective Regulation and 
Control of the Minerals Trade in Eastern Democratic Republic of the 
Congo, [hyperlink, http://www.gao.gov/products/GAO-10-1030] 
(Washington, D.C.: Sept. 30, 2010). 

[2] M-23 was created in May 2012 in eastern DRC and surrendered to DRC 
forces in November 2013. 

[3] United Nations Security Council, "Letter dated 12 December 2013 
from the Group of Experts on the Democratic Republic of the Congo 
addressed to the Chair of the Security Council Committee established 
pursuant to resolution 1533 (2004) concerning the Democratic Republic 
of the Congo," Annex to "Letter dated 22 January 2014 from the 
Coordinator of the Group of Experts on the Democratic Republic of the 
Congo addressed to the President of the Security Council," S/2014/42 
(Jan. 23, 2014). 

[4] 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 (coltan), cassiterite, and wolframite are the ores 
from which tantalum, tin, and tungsten, respectively, are processed. 

[5] In this report, the countries adjoining DRC--Angola, Burundi, 
Central African Republic, the Republic of the Congo, Rwanda, South 
Sudan, Tanzania, Uganda, and Zambia--are often termed "Dodd-Frank 
affected countries." 

[6] Under the rule, SEC-reporting companies with "necessary" conflict 
minerals in products they manufactured or contracted to have 
manufactured must conduct a "reasonable country of origin inquiry" to 
determine whether their conflict minerals originated in the DRC or 
adjoining countries. If none of their conflict minerals originated in 
that region, they must file a Form SD to disclose the reasonable 
country of origin inquiry they conducted and the results. If any of a 
company's "necessary" conflict minerals originated in the DRC or 
adjoining countries, the company must exercise due diligence on the 
source and chain of custody of its conflict minerals and also file a 
Conflict Minerals Report. 

[7] GAO, The Democratic Republic of the Congo: Information on the Rate 
of Sexual Violence in War-Torn Eastern DRC and Adjoining Countries, 
[hyperlink, http://www.gao.gov/products/GAO-11-702] (Washington, D.C.: 
July 13, 2011); Conflict Minerals Disclosure Rule: SEC's Actions and 
Stakeholder-Developed Initiatives, [hyperlink, 
http://www.gao.gov/products/GAO-12-763] (Washington, D.C.: July 16, 
2012); SEC Conflict Minerals Rule: Information on Responsible Sourcing 
and Companies Affected, [hyperlink, 
http://www.gao.gov/products/GAO-13-689] (Washington, D.C.: July 18, 
2013). In our 2012 report, we addressed, for example, a congressional 
mandate that asked us to describe any issues that the SEC encountered 
in promulgating a conflict minerals disclosure rule. In our 2013 
report, we addressed, for example, a mandate that asked us to describe 
information that may be publicly available about entities that use 
conflict minerals but are not required to report to SEC under the rule. 

[8] Stakeholders include relevant U.S. agencies; foreign governments; 
multilateral organizations, such as the Organization for Economic 
Cooperation and Development (OECD); nongovernmental organizations 
(NGOs); and industry associations. 

[9] [hyperlink, http://www.gao.gov/products/GAO-13-689]. 

[10] [hyperlink, http://www.gao.gov/products/GAO-13-689]. 

[11] [hyperlink, http://www.gao.gov/products/GAO-13-689]. 

[12] The Office of the High Commissioner for Human Rights and the 
United Nations Organization Stabilization Mission in the Democratic 
Republic of the Congo (MONUSCO) issued a report in May 2013 on mass 
rapes and other violations of human rights committed in Minova, a town 
in South Kivu, and surrounding areas in November 2012. The report 
documented 135 cases of sexual violence perpetrated by elements of the 
Congolese national army in and around the town of Minova as units 
retreated from the front lines. 

[13] The eleven signatories to the framework were Angola, Burundi, the 
Central Africa Republic, the DRC, the Republic of the Congo (also 
known Congo-Brazzaville), Rwanda, South Africa, South Sudan, Tanzania, 
Uganda, and Zambia. The UN Secretary-General, the Chairperson of the 
African Union Commission, the Chairperson of the Southern African 
Development Community, and the Chairperson of the International 
Conference on the Great Lakes Region signed the agreement as 
witnesses. In January 2014, two additional countries, Kenya and Sudan, 
also signed the framework. According to the UN, the framework 
encompasses commitments at the national, regional and international 
levels to bring peace and stability to the eastern DRC and the region. 

[14] 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. 

[15] Pub. L. No. 109-456. 

[16] Initially, MONUC's focus was on the ceasefire and disengagement 
of forces and maintenance of liaison with all parties involved with 
the civil war, but the operation expanded to include the effective 
protection of civilians, humanitarian personnel, and human rights 
defenders under imminent threat of physical violence. 

[17] According to the UN, the envoy's key tasks include undertaking 
good offices to strengthen the relations between the signatories of 
the framework, revitalizing existing accords and coordinating the 
international engagement. 

[18] The mandate of the force intervention brigade was renewed by the 
UN Security Council until March 2015. 

[19] Canada also has a proposed conflict minerals initiative. 
According to State, Canada's Conflict Minerals Act was reintroduced 
for discussion in the Canadian parliament in April 2014 and would 
require Canadian companies to exercise due diligence in respect of the 
exploitation and trading of designated conflict minerals originating 
in the Great Lakes Region of Africa. 

[20] 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. Organization 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, [hyperlink, 
http://dx.doi.org/10.1787/9789264185050-en]. 

[21] Artisanal mining is a form of mining characterized by a lack of 
mechanization or capital investment. 

[22] According to a World Gold Council representative, in most cases 
refiners are paid a fee to refine gold and the transaction is 
conducted by the miner, the trader, and the bank. 

[23] See [hyperlink, http://www.gao.gov/products/GAO-12-763]. 

[24] Organization for Economic Cooperation and Development, OECD Due 
Diligence Guidance for Responsible Supply Chains of Minerals from 
Conflict-Affected and High-Risk Areas: Second Edition (Paris: November 
2012). 

[25] The Project Management Institute, The Standard for Program 
Management (2013). 

[26] The Act states that a strategy be submitted to Congress no later 
than 180 days after the enactment of the law. 

[27] The Act requires that State should update its map every 180 days. 

[28] IPIS has also published a report that analyzes the information it 
collects and populates in its interactive map. See International Peace 
Information Service, Analysis of the Interactive Map of Artisanal 
Mining Areas in Eastern DR Congo, (Antwerp, Belgium: November 2013), 
accessed June 23, 2014, [hyperlink, 
http://ipisresearch.be/mapping/webmapping/drcongo]. 

[29] [hyperlink, http://www.gao.gov/products/GAO-13-689]. 

[30] 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). In response to the 
appeals court's findings, 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 either by 
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 (1) as "DRC conflict free" (2) as 
having "not been found to be 'DRC conflict free'," or (3) as "DRC 
conflict undeterminable" in their reports. The guidance also states 
that a company may voluntarily elect to describe any of its products 
as "DRC conflict free" 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, the 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 2014, the appeals court denied the motion. 

[31] Pub. L. No. 111-203, sec 1502(b). The Act required that a rule 
should be promulgated no later than 270 days after the law's 
enactment. As we reported in 2012, SEC's issuance of the rule 
encountered delays, including delays in developing, modifying, and 
finalizing the rule, as a result of several factors. See [hyperlink, 
http://www.gao.gov/products/GAO-12-763]. Also see appendix III for a 
flowchart summarizing the conflict minerals rule that SEC published 
when the rule was adopted in 2012. 

[32] The SEC rule indicates that if the deadline for filing the 
conflict mineral disclosure report occurs on a weekend, or on a 
holiday which the SEC is not open for business, then the deadline 
shall be the next business day. 

[33] According to the rule, for a temporary period following the 
effective date of the rule--4 years for smaller reporting companies or 
2 years for all other reporting companies--if a company is unable to 
determine whether the minerals in its products originated in DRC or 
the adjoining countries or financed or benefited armed groups in those 
countries, then those products are considered "DRC conflict 
undeterminable" and no audit is required. According to SEC officials, 
as a result of the SEC's partial stay order and the SEC staff's 
statement, companies are not required to describe their products in 
their reports as "DRC conflict undeterminable" pending further action 
by the SEC or a court, and no audits are required unless a company 
voluntarily describes any of its products as "DRC conflict free" in 
its Conflict Minerals Report. 

[34] The Act also requires Commerce to annually report (1) an 
assessment of the accuracy of the independent private sector audits 
and other due diligence processes required under section 1502 and (2) 
recommendations for the processes to carry out such audits, including 
ways to improve the accuracy of the audits and to establish standards 
of best practices. Commerce officials stated that it was unable to 
implement these aspects of the Act's requirement because the SEC 
disclosure reports, which are needed for the assessment, were not due 
to SEC until June 2, 2014. 

[35] Our 2013 report identified 82 smelters and refiners of tin, 
tantalum, tungsten, and gold located in China, of the 278 smelters and 
refiners that we identified worldwide. 

[36] According to USAID, it holds two of the four government positions 
on the Committee in addition to State and the ICGLR. There are four 
civil society and four private sector members of the Committee as well. 

[37] According to an NGO report, the objective of mineral trading 
centers, or centre de negoce, is to provide a center where miners and 
traders can do business without interference from armed groups. The 
report notes that, at the same time, state agents can exert control 
and levy taxes, traders can receive the necessary paperwork, and 
miners can profit from a market environment in which they can 
negotiate better prices for their products. 

[38] The Regional Steering Committee, comprising technical experts 
from all ICGLR member states, has been charged with the steering of 
all activities within the initiative since September 2009. Its 
suggestions on policies and technical guidelines are to be approved at 
a later stage by the Regional Inter-Ministerial Committee as well as 
the ICGLR Summit. 

[39] [hyperlink, http://www.gao.gov/products/GAO-13-689]. 

[40] [hyperlink, http://www.gao.gov/products/GAO-13-689]. 

[41] CFSI was founded in 2008 by members of the Electronic Industry 
Citizenship Coalition (EICC) and the Global e-Sustainability 
Initiative (GeSI). According to EICC and GeSI, as of April 30, 2013, 
CFSI now includes EICC and GeSI activities and is an expanded 
initiative of the EICC and GeSI Extractives Working Group, which 
includes more stakeholders and a wider range of industry sectors 
supporting the sourcing of conflict-free minerals. 

[42] The actual number of smelters and refiners of conflict minerals 
is unknown. However, in 2013, we reported that the total number of 
smelters and refiners worldwide could be as high as 500. See 
[hyperlink, http://www.gao.gov/products/GAO-13-689]. 

[43] The World Bank defines "civil society" as referring to the wide 
array of nongovernmental and not-for-profit organizations that have a 
presence in public life, expressing the interests and values of their 
members or others, based on ethical, cultural, political, scientific, 
religious, or philanthropic considerations. 

[44] LBMA oversees the London Good Delivery List, a list of 67 
accredited gold refiners that meet a specific standard for the quality 
of their refined gold and silver bars. According to LBMA 
representatives, most banks and exchanges will only contract with 
refiners on the Good Delivery List. 

[45] The Responsible Jewellery Council launched its chain-of-custody 
program to also help its member companies identify and track the 
supply chains of other precious metals, such as platinum, palladium, 
and rhodium. Chain of custody refers to the paper trail that documents 
the sequence of entities with custody of minerals as they move through 
a supply chain. 

[46] Officials of the Responsible Jewellery Council reported that the 
council has developed cross-recognition agreements with CFSI, LBMA, 
and the World Gold Council to reduce unnecessary duplicative audits 
for their member companies. For example, according to an LBMA 
official, once LBMA approves a third-party audit, verifying that a 
gold refiner is conflict-free, the association contacts CFSI to add 
the refiner to CFSI's list of compliant smelters and refiners. 

[47] According to iTSCi, as of November 2013, the traceability program 
is used at more than 850 mines in the South Kivu, Maniema, and Katanga 
provinces of the DRC and in Rwanda. Almost all in-region responsible 
sourcing initiatives--including Solutions for Hope and the Conflict-
Free Tin Initiative--use iTSCi's traceability system of tracking 
minerals from the mine to the exporter to ensure that their minerals 
are conflict-free. 

[48] According to Solutions for Hope, its closed pipeline involved 
working through a defined set of key suppliers--mines (including 
artisanal cooperatives), smelter/processor, component manufacturer, 
and end user--identified in advance of initiating the project. 

[49] According to Solutions for Hope officials, a tin smelter in the 
Katanga province is currently idle due to lack of consistent power, 
and another smelter in Rwanda, which is working toward certification 
by the Conflict-Free Smelter Program, has been idle for over 5 years. 

[50] According to an iTSCi official, the governance assessments also 
include summaries of all incidents that have occurred and how they 
have been mitigated or otherwise resolved. 

[51] ICF International implements the Demographic and Health Surveys 
(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. 

[52] U.S. Department of State, Bureau of Democracy, Human Rights and 
Labor, Country Reports on Human Rights Practices for 2013, accessed 
May 18, 2014, [hyperlink, 
http://www.state.gov/j/drl/rls/hrrpt/humanrightsreport/index.htm#wrapper
]. 

[53] UN Security Council, Report of the Secretary-General on the 
United Nations Organization Stabilization Mission in the Democratic 
Republic of the Congo, S/2013/757 (New York, NY: Dec 17, 2013). 

[54] Progress and Obstacles in the Fight Against Impunity for Sexual 
Violence in the Democratic Republic of the Congo, United Nations Joint 
Human Rights Office, April 2014. 

[55] Extent of Sexual Violence in the DRC and Actions to Fight against 
the Phenomenon of 2011 to 2012, DRC Ministry of Gender, the Family, 
and Child; Kinshasa, June 2013. This report was not publicly available 
before we issued our report in July 2013. 

[56] Medecins sans Frontieres, Everyday Emergency: Silent Suffering in 
the Democratic Republic of Congo, Amsterdam, 2014. 

[57] GAO, SEC Conflict Minerals Rule: Information on Responsible 
Sourcing and Companies Affected, [hyperlink, 
http://www.gao.gov/products/GAO-13-689] (Washington, D.C.: July 18, 
2013). 

[58] GAO, Conflict Minerals Disclosure Rule: SEC's Actions and 
Stakeholder-Developed Initiatives, [hyperlink, 
http://www.gao.gov/products/GAO-12-763 (Washington, D.C.: July 16, 
2012) and [hyperlink, http://www.gao.gov/products/GAO-13-689]. 

[59] [hyperlink, http://www.gao.gov/products/GAO-13-689]. We did not 
include in our current report information from preliminary studies or 
reports. 

[60] [hyperlink, http://www.gao.gov/products/GAO-13-689]. 

[61] Because the data were not used to support findings, conclusions, 
or recommendations, we did not assess their reliability. 

[62] Detailed data showing production and exports of each of the 
conflict minerals are proprietary to iTSCi members. 

[63] The DRC Ministry of Mines statistics also include production and 
export data for other minerals. Because the data were not used to 
support findings, conclusions, or recommendations, we did not assess 
their reliability. 

[64] Because the data were not used to support findings, conclusions, 
or recommendations, we did not assess their reliability. 

[65] The Trade Map (or Market Access Map, Investment Map and Standards 
Map, respectively), International Trade Centre, [hyperlink, 
http://www.intracen.org/marketanalysis]. 

[66] Because the data were not used to support findings, conclusions, 
or recommendations, we did not assess their reliability. 

[End of section] 

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