Conflict Minerals Reporting Requirements
Conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than June 2, 2025.1 The conflict minerals disclosure rules and related guidance have remained at a...more
Securities and Exchange Commission (SEC) reporting companies with fiscal years ending December 31 that engage in the commercial development of oil, natural gas or minerals are required to file a Form SD with the SEC by...more
As discussed in our January 10, 2024 webinar, new SEC rules require resource extraction issuers that file reports with the SEC to file a Form SD within 270 days after each fiscal year end to report their payments to the U.S....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
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
Development International has posted its most recent Conflict Minerals Benchmarking Study, analyzing the results of filings for the 2016 filing period. The study looked at filings submitted by the 1,153 issuers that had filed...more
Effective immediately, the SEC staff has relaxed conflict minerals reporting requirements by public companies. The change was triggered by the entry of a final judgment in the conflict minerals case. ...more
On January 31, 2017, Michael Piwowar, Acting Chairman of the Securities and Exchange Commission (the “SEC”), issued two Statements regarding the current status of guidance on and implementation of the conflict minerals rules....more
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
The U.S. Securities and Exchange Commission (the “SEC”) has adopted new rules which require “resource extraction issuers” to disclose annually the type and amount of payments that they (or their subsidiaries or entities under...more
On June 27, 2016, the U.S. Securities and Exchange Commission (“SEC”) adopted Rule 13q-1 under the Securities Exchange Act of 1934 (the “Exchange Act”) and amendments to Form SD (Specialized Disclosure Report) (See SEC...more
On June 27, the Securities and Exchange Commission (“SEC”) issued a new rule requiring extractive sector companies (oil, gas, and mining) to disclose the payments that they make to governments for the commercial development...more
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
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
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
A standard part of every financial statement audit is providing the auditor a representation letter reaffirming certain assertions that are implicit in preparation of financial statements in accordance with GAAP. The AICPA...more
Form SD provides that companies are to file the conflict minerals report as Exhibit 1.01, as does the SEC final release. Last year, however, Exhibit 1.01 was not technically available for EDGAR filings, and the SEC’s EDGAR...more
International Trade Partner Ron Oleynik and Public Affairs Advisor Paolo Mastrangelo succinctly explain the due diligence process for companies with conflict minerals in their products and the need for transparency in their...more
A law firm has submitted a rule making petition to the SEC to amend the rule governing the conflict minerals disclosure on Form SD to permit, for a temporary period, an alternative disclosure. The petition states “based upon...more