Conflict Minerals Reporting Requirements
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The New SEC Conflict Minerals Rule: Overcoming the Challenges of Compliance
Conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2024. The conflict minerals disclosure rules and related guidance have remained at...more
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, 2023. The conflict minerals disclosure rules and related guidance have remained at a...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
Although the EU Conflict Minerals Regulation no. 2017/821 of 17 May 2017 (the CMR) entered into force on 1 January 2021, there has been no sign of any national enforcement system in Belgium so far. The Belgian Government has...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
Companies are increasingly focusing on the environmental, social and governance (ESG) aspects of their businesses. In 2019, 90% of the S&P 500 index companies published sustainability reports. In contrast, in 2011, only 20%...more
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
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
In a public vote on 29 November 2020, the Swiss electorate rejected the Responsible Business Initiative (the “RBI”). After an intensive ideological campaign, the RBI received 50.7% of the votes but failed to win support in a...more
On December 2, 2020, the Supreme Court of Ohio issued its opinion in West v. Bode, 2020-Ohio-5473, and determined that either the Marketable Title Act (“MTA”) or the Dormant Mineral Act (“DMA”) may be used to reunite a...more
In a closely-watched case that carried potentially drastic consequences, on December 2, 2020, the Supreme Court of Ohio issued its decision in West v. Bode, 2020-Ohio-5473. In a close 4-3 decision, the Court held that there...more
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
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
On November 5, 2019, the Securities and Exchange Commission (SEC) proposed amendments to its rules governing proxy solicitations. If adopted in their current form, these proposals could significantly affect interactions...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
Under Dodd-Frank, the GAO is required to assess annually the effectiveness of the SEC’s conflict minerals rules in promoting peace and security and to report on the rate of sexual violence in the DRC and adjoining countries....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
I visited with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, Corporate Social Responsibility (CSR) value propositions, the...more
As a reminder, conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2019. There have not been any notable regulatory updates related to the...more
This from consultant Elm Sustainability: Elm advises that companies working on their conflict minerals reporting should not be surprised to see a decline in the number of their audited smelters and refiners...more
Mounting pressure on businesses to gain clarity on their social and environmental footprint will challenge corporate operations in 2019. New risks are present but there are also opportunities for companies willing actively to...more
In an en banc decision issued yesterday, the Ninth Circuit Court of Appeals reversed U.S. District Court Judge Edward M. Chen's denial of a preliminary injunction in an action challenging a San Francisco ordinance requires...more
Tiffany & Company announced last week that it would become the world’s first jewelry company to share with its consumers information about the country of origin of each diamond they sell. This is the first in a step of...more