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Due Diligence Conflict Mineral Rules Securities and Exchange Commission (SEC)

Cooley LLP

GAO reports on conflict minerals compliance in 2022

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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

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due June 1, 2021

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

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due June 1, 2020, Despite COVID-19

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, 2020. This remains true despite the impact of COVID-19, given that...more

Stinson - Corporate & Securities Law Blog

Survey of 2016 Conflict Minerals Filings Released

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

BakerHostetler

Conflict Minerals Disclosure New SEC Guidance

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On April 7, 2017, the Securities and Exchange Commission ("SEC") Division of Corporate Finance (the "Division") indicated that it will not recommend enforcement of the conflict minerals source and chain of custody due...more

Cooley LLP

Blog: GAO Issues Annual Report Showing Only Slight Progress In Disclosures On Conflict Minerals

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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

Stinson - Corporate & Securities Law Blog

GAO Reports on 2015 Conflict Minerals Form SDs

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

Foley Hoag LLP - Global Business and Human...

Five on Friday – Five Recent Developments that We’ve Been Watching Closely

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

Foley Hoag LLP - Global Business and Human...

The SEC and the Conflict Minerals Rule: What You Need to Know about the Latest Developments

It is clear that Michael Piwowar, Acting Chairman of the Securities Exchange Commission (“SEC”) is not a fan of the conflict minerals rule. Earlier this month, the Acting Chairman and the Division of Corporation Finance...more

Cooley LLP

Blog: Senate Hearing On Conflict Minerals Law Reveals Common Theme

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On April 5, just prior to the release of Corp Fin’s Updated Statement on conflict minerals, the Senate Subcommittee on Africa and Global Health Policy held a hearing on the effects on the Democratic Republic of the Congo of...more

Parker Poe Adams & Bernstein LLP

Conflict Minerals - What Just Happened and What Didn’t

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

Beveridge & Diamond PC

New Developments and Uncertainties for Conflict Minerals Disclosure

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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

Cooley LLP

Blog: State Department ventures into conflict minerals

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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

Foley Hoag LLP - Global Business and Human...

Five on Friday – Five Recent Developments that We’ve Been Watching Closely - February 2017

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

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Acting Chairman Directs Reconsideration of Conflict Minerals Rule"

The acting chairman of the U.S. Securities and Exchange Commission (SEC), Michael S. Piwowar, recently released two public statements concerning the conflict minerals rule applicable to companies that file Exchange Act...more

Cooley LLP

Blog: Corp Fin Deputy Director Comments On Conflict Minerals Compliance

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In remarks at the PLI Securities Regulation Institute yesterday, Corp Fin Deputy Director (Disclosure Operations) Shelley Parratt confirmed, as we all suspected, that it’s status quo on conflict minerals reporting again this...more

Foley Hoag LLP - Global Business and Human...

Five on Friday – Five Recent Developments that We’ve Been Watching Closely: September 2016 #2

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

Cooley LLP

Blog: GAO Issues Second Annual Conflict Minerals Report

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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

Stinson - Corporate & Securities Law Blog

GAO Says Companies Face Continuing Challenges in Determining Whether Their Conflict Minerals Benefit Armed Groups

GAO noted in a recent report that as a result of country-of-origin inquiries, an estimated 19 percent more companies that filed Form SD with the SEC reported that they knew or had reason to believe they knew the source of the...more

Cooley LLP

Blog: Consultants Report On Conflict Minerals Due Diligence And Disclosure For 2015. But Has It Made A Difference For The DRC?

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Two consulting firms, Assent Compliance and Source Intelligence, have published their studies on conflict minerals (tin, tantalum, tungsten and gold) reporting for 2015, the third year of required SEC reporting. For 2015,...more

Stoel Rives LLP

In Case You Missed It - Interesting Items for Corporate Counsel - May 2016

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The SEC, along with the Department of the Treasury, the Federal Reserve System, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, and the National Credit Union Administration, proposed a joint...more

Orrick, Herrington & Sutcliffe LLP

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

Cooley LLP

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

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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

Cooley LLP

Blog: This Year’s Conflict Minerals Filings Show Some Improvement, According To Early Review

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An early review of conflict minerals filings for the 2014 reporting period shows improvement in “detail, clarity and quality,” according to this article in BNA. As reported by Elm Sustainability Partners, a conflict minerals...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Conflict Minerals Disclosures Due June 1, 2015"

Conflict minerals disclosures on Forms SD for calendar year 2014, if required, must be filed with the U.S. Securities and Exchange Commission (SEC) by June 1, 2015 — the Monday after the annual May 31 due date. As companies...more

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