Conflict Minerals Reporting Requirements
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The New SEC Conflict Minerals Rule: Overcoming the Challenges of Compliance
The GAO has just issued its 2022 Report on Conflict Minerals, which examines companies’ conflict minerals compliance in 2022. As you probably know, the SEC’s conflict minerals rules were originally mandated by Congress in an...more
Conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2022. The conflict minerals disclosure rules and related guidance have remained at...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
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
We have been talking about conflict minerals for years. And, so have our manufacturing clients. As covered previously in this blog, the conflict minerals laws and regulations are some of the most well known, but least...more
GAO released an analysis of a generalizable sample of conflict minerals disclosures filed with SEC in 2015. The analysis found that an estimated 49 percent of companies in 2015 reported having determined whether the conflict...more
The European Conflict Minerals Regulation (the Regulation) was approved by the European Council on 3 April 2017. Publication in the Official Journal of the European Union will be the next step in the process and this could...more
The conflict minerals saga continues. Background - In April 2014, the Court of Appeals for the D.C. Circuit in National Association of Manufacturers v. SEC held that the conflict minerals rule’s requirement that...more
The Securities and Exchange Commission (SEC or Commission) Division of Corporate Finance issued a new statement adding some uncertainty to company obligations and enforcement exposure under the SEC conflict minerals rule...more
In the wake of the US elections in November 2016, two of the Securities and Exchange Commission’s (“SEC”) disclosure rules for public reporting companies — the conflict minerals rule and government payments reporting for...more
It’s Friday and time for another overview of developments in the field of business and human rights that we’ve been monitoring. This week’s post includes: the GAO’s latest report on the conflict minerals rule; a civil...more
Seyfarth Synopsis: Companies are experiencing difficulties in complying with their disclosure responsibilities under the SEC’s conflict mineral requirements. The Government Accountability Office (GAO) recently released a...more
Last year, we provided an overview regarding the requirement that U.S. publicly traded companies disclose their use of “conflict minerals.” As of 2014, the Government Accounting Office reported that 1,321 companies filed the...more
Apple has filed its Form SD for the year ended December 31, 2015. It includes this disclosure: The combination of training, public reporting and a ticking clock drove the number from 82 smelters and refiners...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