News & Analysis as of

Conflict Minerals: D.C. Circuit to Reconsider Conflict Minerals Ruling; Initiatives Proceed in the European Union and China

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

Don’t Forget About Conflict Minerals

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

Second Conflict Minerals Report Filed

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

Court Invalidates Conflict Minerals Rule Because It Crosses First Amendment Line

In the end, it’s pretty simple. The court held the conflicts minerals rule and statute embodied in Dodd-Frank violate the First Amendment to the extent the statute and rule require regulated entities to report to the...more

7 Tips for Complying with the Conflict Minerals Rule

With the recent publication of Form SD, the disclosure form that all companies subject to the Conflict Minerals Rule must file with the Securities and Exchange Commission (SEC), it is a good time to brush up on the Rule’s...more

The Compliance Crystal Ball—Top 10 Compliance Trends For 2014

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

Group Identifies Conflict Minerals Report Expectations

The Responsible Sourcing Network has released a paper, the goal of which is to describe the content that certain sustainable and responsible investors, or SRIs, and nongovernmental organizations, or NGOs, expect to see in an...more

Federal Court Upholds Conflict Minerals Rules, As Time Grows Short To Complete Supply Chain Due Diligence

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

Conflict Minerals: Key Initial Compliance Steps for Companies

The SEC’s conflict minerals reporting rules became effective January 1, 2013, and those rules impose burdens on companies throughout the automotive supply chain, given how prevalent the so-called “conflict minerals” are in...more

Complying with the SEC’s Conflict Minerals Rules

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

Perils of the Global Supply Chain, Part 2: Supply Chain Responsibility, Or Else.

Twenty years ago less than 100 companies worldwide disclosed or reported on their supply chain compliance or corporate social responsibility (CSR) practices. Those that did were trailblazers supporting the idea that...more

The Conflict Minerals Report’s Content and Supply Chain Due Diligence

The SEC describes application of the conflicts mineral rule as a three step process: Step 1: An issuer must determine whether it is subject to the requirements of the conflict minerals statutory provision. The...more

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