Sarah A. Altschuller

Sarah A. Altschuller

Foley Hoag LLP

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D.C. Circuit Largely Upholds SEC’s Conflict Minerals Rule But Supports First Amendment Challenge

On April 14, the D.C. Circuit Court of Appeals issued an opinion in National Association of Manufacturers v. SEC, a case that sought to challenge the conflict minerals rule released by the Securities and Exchange Commission...more

4/17/2014 - Conflict Mineral Rules First Amendment Manufacturers SEC

Foley Hoag Authors Good Practice Note on Indigenous Peoples’ Rights and Free, Prior, and Informed Consent

The U.N. Global Compact recently released a Good Practice Note on Indigenous Peoples’ Rights and the Role of Free, Prior, and Informed Consent (“FPIC”) authored by Amy Lehr, an associate in Foley Hoag’s Corporate Social...more

4/1/2014 - FPIC Indigenous Peoples Informed Consent International Finance United Nations

Protests Against Surveillance and New Rules on Transparency

Today, February 11, is a digital day of protest against surveillance by the National Security Agency. Billed ‘The Day We Fight Back“, participants in the protest range from activist groups to the Reform Government...more

2/11/2014 - NSA Privacy Laws Right to Privacy Surveillance Transparency

After the Super Bowl: Human Trafficking Occurs More Than Once a Year

Over the past week, significant attention has been paid to the risks of sex trafficking associated with the Super Bowl. Law enforcement resources were dedicated to identifying traffickers and ensuring that services are...more

2/4/2014 - Due Diligence Human Trafficking Supply Chain

Building Capacity to Exercise Good Judgment in a World of Big Data

This week the news has been full of reports from Las Vegas regarding the latest technological trends on display at the International Consumer Electronics Show. Discussions about wearable technologies and smart appliances —...more

1/10/2014 - Big Data Cybersecurity Data Protection Internet of Things Mobile Devices

“Hardening” Soft Law and Human Rights Expectations for Financial Institutions

Earlier this month, a group of global banks known as the Thun Group released a discussion paper exploring the ways in which financial institutions might seek to integrate the U.N. Guiding Principles on Business and Human...more

11/1/2013 - Banks Corporate Social Responsibility EU Human Rights OECD United Nations

U.S. District Court Upholds the Conflict Minerals Rule

On July 23, the District Court for the District of Columbia rejected a challenge to the conflict minerals rule adopted by the Securities and Exchange Commission in August 2012 and published in September 2012. Plaintiffs...more

7/26/2013 - Administrative Procedure Act Conflict Mineral Rules Country of Origin Disclosure Requirements First Amendment Free Speech SEC

Corporate Transparency Reports: Understanding Limitations and Leveraging Opportunities

Recent revelations regarding surveillance activities by the U.S. Government have raised many questions regarding the balance between privacy and security. There have already been, and there will continue to be, Congressional...more

6/24/2013 - Electronic Frontier Foundation Facebook FISA Google LinkedIn National Security Public Disclosure Surveillance Transparency Twitter

ICMM Releases Position Statement on Indigenous Peoples Establishing Commitment to FPIC

The International Council of Mining & Metals (“ICMM”) recently released a position statement on indigenous peoples and mining that explicitly requires its 22 member companies to work to obtain the free, prior, and informed...more

5/31/2013

Responding to Investor Concerns Regarding Human Rights Impacts

Increasingly, companies will face explicit demands from investors, especially members of the socially responsible investor community, that they provide detailed disclosures regarding internal processes and procedures to...more

5/21/2013 - Corporate Social Responsibility Human Rights Investors

Reflections on the Evolving Business and Human Rights Agenda

As mentioned in last week’s post, participants in the Voluntary Principles Initiative recently held their Annual Plenary Meeting. The discussions began with opening addresses from Professor John Ruggie, the former U.N....more

4/5/2013 - Corporate Social Responsibility Due Diligence Human Rights United Nations

Participants in the Voluntary Principles Initiative Gather for 2013 Annual Plenary Meeting

On March 13-14, participants in the Voluntary Principles Initiative gathered in The Hague for the 2013 Annual Plenary Meeting. Foley Hoag’s Corporate Social Responsibility (“CSR”) practice has served as the Secretariat for...more

3/29/2013 - Corporate Social Responsibility

Telecommunications Companies Release Guiding Principles on Freedom of Expression and Privacy

The Telecommunications Industry Dialogue, a group of eight telecommunications companies, recently published a set of Guiding Principles on freedom of expression and privacy. Originally formed in 2011, the Industry Dialogue...more

3/26/2013 - Data Protection Due Diligence Freedom of Expression Human Rights Safety Precautions Telecommunications Training

Board Oversight of CSR & The Role of the CSR Committee

Shareholders increasingly expect boards of directors to exercise greater oversight over the social and environmental impacts of corporate activities. The 2013 Proxy Preview recently published by As You Sow, the Sustainable...more

3/12/2013 - Corporate Governance Corporate Social Responsibility

Due Diligence on Human Rights? Consider Consulting Your FPCA Counsel.

Human rights due diligence requires many of the hallmarks of existing corporate compliance programs: clear policies; assessments of risk; and the integration of strong standards into corporate management systems. This...more

2/8/2013 - Compliance Due Diligence FCPA Human Rights

Looking Ahead: Five Developments We’ll be Watching in 2013

As memories of New Year’s Eve fade, and another Inauguration Day winds down in Washington, D.C., it’s time to look ahead and identify key events and emerging trends that we think will help shape the business and human rights...more

1/22/2013 - Alien Tort Statute Corporate Social Responsibility Due Diligence Human Rights Human Trafficking Supply Chain

Benefit Corporations: Twelve States and Counting

On December 1, a new benefit corporation statute went into effect in Massachusetts, making the state one of twelve that have enacted legislation allowing for the formation of this new form of corporate entity....more

12/20/2012 - Benefit Corporations Corporate Social Responsibility

John Ruggie Gives Opening Address at U.N. Forum on Business and Human Rights

On December 4 and 5, more than 1,000 participants from 85 countries gathered for the first U.N. Forum on Business and Human Rights in Geneva, Switzerland. The Forum focused on “trends and challenges” in the implementation of...more

12/11/2012 - Conflict Mineral Rules Dodd-Frank Due Diligence Human Rights United Nations

Petitioners Challenging Conflict Minerals Rule File Preliminary Statement of Issues and Proposed Briefing Schedule

On November 21, petitioners challenging the SEC’s new conflict minerals rule filed a “Preliminary Statement of Issues” with the D.C. Circuit Court of Appeals, setting forth an overview of the challenges they intend to raise...more

11/27/2012 - Conflict Mineral Rules SEC

SEC Rejects Request to Stay New Extractive Industry Transparency Rule

On November 8, the Securities and Exchange Commission (“SEC”) rejected a request by industry groups to stay new regulations requiring disclosure of payments to governments relating to oil, gas, and mining projects. The...more

11/12/2012

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