Waar laat je die joppies?

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Overall, I also (grudgingly) support the Bill. While I hate to be ficikny, the details do matter. Some clarifications: The bill requires disclosure of minerals (tin, tantalum, tungsten and gold) from the Congo or "adjoining countries", thus having potential ramifications for all of central Africa (yes, yes, even large-scale industrial mining in Tanzania, Zambia, Angola...). It also allows for the Secretary of State to determine additional "conflict minerals" to be added to the list without any legislative oversight. (However, as we all know, the State Dept has received such hell for this in Kinshasa and elsewhere - that any future designation is unlikely.) It is unclear to whom the bill would actually apply: those "persons" required to disclose annual reports under S. 13 of SEC 1934 AND where "conflict minerals are necessary to the functionality or production of a product manufactured by such person". Does this mean only those companies involved in, and downstream from, manufacturing? The Secretary of State only has to outline a plan to provide due diligence guidance to companies, not provide guidance itself. As you noted, the Bill does not say what due diligence actually means. It is unlikely that the SEC would want to define this in any specific manner (to avoid potential conflict with other SEC conceptions of due diligence and to reduce the oversight burden). It is likely however that OECD and UNGoE conceptions of due diligence will be determined as "reliable" and noted in preambular language to the SEC regulations, as these will most likely become the