Conflict Minerals Reporting Requirements
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
As noted in this Law 360 article and in this thecorporatecounsel.net blog , on Friday, the SEC filed a Notice of Proposed Rulemaking in the U.S. District Court for the District of Massachusetts in connection with Oxfam...more
It’s that time of year again. Form SD filings are due June 1st (May 31st falls on a Sunday). For those who have been diligently working on your company’s annual report and proxy statement, it is time to turn your attention...more
The first wave of Form SD filings has come and gone, leaving us with more insight into supply chains and manufacturing processes than most of us ever wanted, yet much uncertainty about the actual sources of the conflict...more
Court denies emergency motion for a stay. By order issued on May 14, 2014, the U.S. Court of Appeals for the District of Columbia denied the appellants’ emergency motion for a stay of the Securities and Exchange...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
The second Form SD and related conflicts minerals report has been filed. They are interesting documents but may still not be the holy grail of precedents because of, among other things, the use of terms like “Conflict Free...more