Subject: File No. DF Title XV - Specialized Disclosures
From: Maneesh Pangasa

November 3, 2010

Chairman Schapiro
Securities and Exchange Commission

Dear Chairman Schapiro,

The recent passage of the Conflict Minerals Act is an important first step in ensuring that U.S. consumers won't take part in fueling the deadliest conflict on earth. By making the supply chains of tin, tungsten, tantalum and gold more transparent, American consumers will be able choose to support companies that take steps to ensure their products are conflict-free, and also free of slavery and other extreme human rights abuses.

Free the Slaves and human rights organizations in Congo have documented abuses against miners in Congo, including forced labor, debt bondage, and hazardous child labor. Other forms of slavery like the use of child soldiers and the prostitution of children also exist in mining areas.

Slavery must not be overlooked in the implementation of the Conflict Minerals Act. The new law requires companies to disclose “due diligence on the source” of conflict minerals originating in the DRC. 15 U.S.C. 78m (p)(1)(A)(i).

Due diligence on the source of these minerals must be defined to include a description of efforts to monitor the source of the supply chain for forms of modern slavery and other extreme violations of human rights.


Maneesh Pangasa
Yuma, AZ 85365