News & Analysis as of

Form SD Supply Chain

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due May 31, 2022

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

Cooley LLP

Blog: GAO issues annual report on conflict minerals filings

Cooley LLP on

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

Cooley LLP

Blog: GAO issues annual report on conflict minerals filings in 2017

Cooley LLP on

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

Cooley LLP

Blog: GAO Report On Gold Supply Chain Reveals Little Progress In Responsible Sourcing

Cooley LLP on

The GAO has issued a new report on conflict minerals focused in this instance on the supply chain for artisanal and small-scale mined (ASM) gold in the DRC region. The report also addressed efforts to encourage responsible...more

Cooley LLP

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

Cooley LLP on

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

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

Beveridge & Diamond PC on

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

Stinson - Corporate & Securities Law Blog

SEC Staff Relaxes Conflict Minerals Reporting

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

Stinson - Corporate & Securities Law Blog

Apple’s Conflict Minerals Smelters Nearly 100% Audited

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

Parker Poe Adams & Bernstein LLP

Conflict Minerals Filings—Round Two

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

Parker Poe Adams & Bernstein LLP

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

Stinson - Corporate & Securities Law Blog

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

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