On Aug. 22, 2012, the U.S. Securities and Exchange Commission ("SEC") adopted  final  rules  to implement  reporting and disclosure  requirements related to "conflict minerals, " as directed by the Dodd - Frank Wall Street Reform and Consumer Protection Act of 2010.   The rules require manufacturers who file certain reports with the SEC to disclose whether the products they manufacture or  contract to  manufacture contain " conflict minerals"  that are "necessary  to the  functionality or production"  of  those products.