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
An assessment of environmental, social, and governance (ESG) factors has become an integral part of the due diligence review of companies. Such assessment may provide a potential acquirer with a detailed analysis of a...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
On January 1, 2021, the Conflict Minerals Regulation (EU Regulation 2017/821) came into full force across the EU. This new law aims to ensure that importers of certain materials originating from conflict-affected and...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
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: a lawsuit by the City of New York seeking compensation for the...more
Development International has released its annual survey of conflict minerals reports for the 2016 reporting period which were filed in 2017. Despite the SEC’s no action position which relaxed conflict minerals reporting...more
The EU has finally adopted new transparency rules regarding so-called conflicts minerals being imported into the EU. This follows a series of policy initiatives from the European Commission to drive for greater transparency...more
The new EU rules on conflict minerals impose strict due diligence requirements on EU importers of gold, tin, tungsten and tantalum. On 19 May 2017 Regulation 2017/821, which sets out supply chain due diligence obligations for...more
The GAO has recently issued its third annual report on conflict minerals. The GAO is required by Dodd-Frank to report annually on the effectiveness of the SEC’s conflict minerals rule in promoting peace and security in the...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
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: a jury verdict in the Quinteros v. DynCorp litigation; the latest...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
On 16 March 2017, the European Parliament approved a draft EU regulation intended to ensure that trade in certain minerals and metals from high-risk or warn-torn areas does not fund conflict and human rights abuses. The...more
Bloomberg BNA is reporting that the State Department has launched a new review of “how best to support responsible sourcing of conflict minerals,” which will continue through April 28. Although it’s not known whether the SEC...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: a federal court decision holding that U.S.-based companies may be...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
The GAO has issued its annual conflict minerals report to Congress, entitled “Companies Face Continuing Challenges in Determining Whether Their Conflict Minerals Benefit Armed Groups.” The GAO is required to report annually...more
Just in time for those Forms SD and conflict minerals reports, due May 31, the OECD has posted a new edition of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk...more
Recent developments in the U.S., European Union and China underscore the dynamic nature of evolving supply chain due diligence requirements and expectations for companies sourcing tin, tantalum, tungsten and gold. The...more
A federal district court in Washington, D.C. has rejected an industry challenge to the Securities and Exchange Commission’s conflict minerals rules (the “Rules”) issued pursuant to Section 1502 of the Dodd-Frank Act....more
Introduction - On August 22, 2012, the U.S. Securities and Exchange Commission (the “SEC”) adopted new rules (the “Final Rules”) pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act...more