First Steps Toward Building a Conflict Minerals Compliance Program


Originally published in Corporate Compliance Insights, December 10, 2012.

On Aug. 22, 2012, the U.S. Securities and Exchange Commission (SEC) adopted rules that are likely to impact the operations of thousands of companies whose securities are traded in the United States. The rules, widely referred to as the “Conflict Minerals Rules,” apply to any company that files reports with the SEC under Sections 13(a) or 15(d) of the Securities Exchange Act of 1934, and manufactures, or contracts to manufacture, a product containing tin, tungsten, tantalum or gold (the so-called “Conflict Minerals”). If any of these minerals are necessary to the functionality or production of a product manufactured or contracted to be manufactured by the company, then the company must submit a new disclosure form (Form SD, a/k/a the “Specialized Disclosure Report”) to the SEC on an annual basis.

The first Forms SD must be filed with the SEC no later than May 31, 2014, covering a company’s use of Conflict Minerals during calendar year 2013.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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