Conflict Mineral Rules Compliance

News & Analysis as of

Managing Legal and Reputational Risks in an Era of Enhanced Transparency

Companies face a range of new requirements and expectations calling for enhanced transparency regarding human rights-related risks in connection with their operations. Responsible compliance with both mandatory requirements...more

Conflict Minerals Disclosure for Calendar Year 2015: "Conflict Undeterminable" Generally No Longer Permitted

The "DRC Conflict Undeterminable" determination, widely employed in conflict minerals reports to date, will not be permitted for issuers (other than small companies) reporting in 2016 on activities in calendar year 2015. At...more

Blog: New GAO Report On Conflict Minerals Compliance

By coincidence, the same day that the three-judge panel of the D.C. Circuit struck down (again) a portion of the conflict minerals rule (see this post), the GAO issued a report to Congressional Committees entitled “SEC...more

Blog: New Study Gives Mixed Reviews To Companies Filing Conflict Minerals Reports

A new study on conflict minerals compliance from Tulane University and Assent Compliance, a compliance software and services firm, revealed that, about 90% of filers of conflict minerals reports indicated that they were...more

Conflict Minerals: European Parliament Endorses New Compliance Requirements

It has been nearly a month since the deadline for companies in the United States to file their second annual conflict minerals reports with the Securities and Exchange Commission. As companies and their stakeholders assess...more

Blog: A Peek Into Corp Fin’s Assessment Of The First Year Of Conflict Minerals Filings

As those who worked on conflict minerals this past year can attest, the SEC was not exactly lavish in providing guidance on the application of its rules. As reported by Bloomberg, director of Corp Fin, Keith Higgins, speaking...more

Conflict Minerals: SEC Position on Non-Metallic Forms of Tin

Shortly before the filing deadline for the first conflict minerals filings on Form SD, it became known that the SEC believed non-metallic forms of tin are not conflict minerals because non-metallic forms of tin are...more

GAO Says Commerce Department Has Not Complied With Conflict Minerals Obligations

The Government Accountability Office, or GAO, has issued a report noting the SEC issued a rule in 2012 requiring certain companies to disclose the source and chain of custody of necessary conflict minerals in their products....more

The Financial Report - Volume 3, No. 10 • May 2014 (Global)

News from the Americas - High-speed trading. Bloomberg discussed US Senate Agriculture Committee hearings on high-speed trading. Former CFTC economist Andrei Kirilenko said that new books and records requirements and...more

Ten Tips to Develop a Practical Conflict Minerals Approach for 2014

As you sit at your desk waiting for any guidance regarding what your Conflict Minerals Report should look like, you may allow yourself to think about June 3, 2014, the day after companies are required to file their Form SD...more

SEC Clarifies Conflict Minerals Reporting Requirements

The Securities and Exchange Commission confirmed this week that it expects companies to timely file reports required under the conflict minerals rule and to comply with other provisions unaffected by a recent appellate...more

The Compliance Crystal Ball—Top 10 Compliance Trends For 2014

It is that time of year again when we dust off the compliance crystal ball and take a look at what might be in store for 2014. 1. Executive Order 13627 Changes Government Contracting - Want a government contract...more

What’s New for the 2014 Proxy Season

Unlike in past years, there are no new disclosure requirements which need to be reflected in this year’s proxy statement; however, with ongoing shareholder activism and the desire of companies to communicate effectively with...more

Judges Sharply Question SEC On Conflict Minerals Rule

Shortly after the Securities and Exchange Commission (“SEC”) adopted its conflict minerals disclosure rule in August 2012, a coalition of business interests filed suit to challenge the SEC’s rule as unduly burdensome. That...more

Top 10 Compliance Trends For 2014

As 2013 wraps up, it is that time of year again when we dust off the compliance crystal ball and take a look at what might be in store for 2014: 1. Executive Order 13627 on Trafficking in Government Contracts —...more

Corporate Communicator - Winter 2014

2014 ANNUAL MEETING SEASON - Dear clients and friends, We present to you our traditional year-end issue of Snell & Wilmer’s Corporate Communicator to help you prepare for the upcoming annual report and proxy...more

D.C. Circuit to Decide Validity of SEC Conflict Minerals Rule, But Companies Should Consider Preliminary Steps to Comply

Industry groups are urging the U.S. Court of Appeals for the D.C. Circuit to reverse a July 23 district court decision (28 CCW 233, 7/31/13) and invalidate a rule issued by the U.S. Securities and Exchange Commission that...more

Navigant Investigations Quarterly 2013 - The Next Compliance Deluge: Understanding Foreign States’ Mandatory Corporate Social...

Corporate Social Responsibility (CSR) has evolved from a “nice idea” or “marketing opportunity” to a true business imperative. Companies are increasingly becoming sophisticated with respect to CSR reporting and are checking...more

SEC Issues Guidance on Conflict Minerals Rule

On May 30, 2013, the Securities and Exchange Commission issued guidance related to the requirement that issuers disclose the use of conflict minerals in their products, as mandated by the 2010 Dodd-Frank Wall Street Reform...more

Conflict Minerals: Key Initial Compliance Steps for Companies

The SEC’s conflict minerals reporting rules became effective January 1, 2013, and those rules impose burdens on companies throughout the automotive supply chain, given how prevalent the so-called “conflict minerals” are in...more

Corporate Law Report: Workplace Romances, FMLA Changes, California Tax News, and More [Video]

Our latest Corporate Law Report includes a look at how to deal with office relationships, changes to FMLA rules to benefit veterans, an unfortunate tax development for investors in certain California business, and other...more

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...more

SEC Posts Small Entity Compliance Guide Regarding Conflict Minerals Disclosure

On November 13, the Division of Corporation Finance of the Securities and Exchange Commission posted A Small Entity Compliance Guide (Compliance Guide) on its website related to the final rule implementing disclosure and...more

Planning for the 2013 Annual Meeting Season

As companies prepare for the 2013 annual meeting and reporting season, we have compiled an overview of the corporate governance and disclosure matters that companies should consider as they draft this season’s disclosure...more

The New SEC Conflict Minerals Rule: Overcoming the Challenges of Compliance

On August 22, the Securities and Exchange Commission (SEC) adopted a controversial and far-reaching rule laying out the obligations that publicly traded companies must meet under the "Conflict Minerals" provisions of the...more

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