Conflict Minerals Reporting Requirements
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The New SEC Conflict Minerals Rule: Overcoming the Challenges of Compliance
As a reminder, conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than June 1, 2021. The conflict minerals disclosure rules and related guidance...more
As economies start to reemerge from COVID crisis mode, environmental, social, and corporate governance (ESG) factors are rising in importance. A global survey conducted by NAVEX Global shows that 67 percent of respondents in...more
Report on Supply Chain Compliance 3, no. 5 (March 5, 2020) - On April 3, 2017, the European Commission adopted a new regulation on mineral imports from conflict-affected areas, the EU Conflict Minerals Regulation. The...more
As corporate responsibility evolves, and the focus on corporate sustainability grows, more businesses in the mining and metals and related sectors are referencing the long-term potential of blockchain technology and platforms...more
On Oct. 1, the U.S. Customs and Border Protection announced withhold release orders covering five imported products from five countries. The companies, ranging from apparel producers in Asia to conflict mineral miners in...more
I visited with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, Corporate Social Responsibility (CSR) value propositions, the...more
The rewards from investing in so-called “frontier markets” are enticing: rapid growth with unexploited niches, often marked by youthful consumers excited with their new found discretionary cash. These are the regions that...more
Acting SEC Chief Limits Subpoena Authority to Enforcement Division Acting Director - On February 15, 2017,The Wall Street Journal reported that the acting Chair of the Securities and Exchange Commission (SEC), Michael...more
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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