As SEC reporting companies finalize their conflict minerals disclosures each year, they typically review the Form SD requirement that calls for a description of any steps taken or to be taken to improve their conflict minerals due diligence. This required disclosure is typically provided in sections called “Actions Taken and to be Taken to Improve
Conflict Minerals Law
The Source for Legal Insights & Analysis on Conflict Minerals Compliance
Blog Authors
Latest from Conflict Minerals Law
Piwowar’s Statement on SECs Conflict Minerals Rule – We Could Have Seen It Coming
In a move that has already been widely reported, on January 31, 2017, the SEC’s Acting Chairman Michael Piwowar issued a statement on the SECs conflict minerals rule, in which he directed the SEC staff to “consider whether the [April] 2014 guidance is still appropriate and whether any additional relief is appropriate in the interim.”…
Conflict Minerals in 2017 – What’s New?
It’s January 2017, and some believe it will be the last year for the SECs conflict minerals rule.
Political and Legislative Environment
President Trump’s inclination to roll back regulation reduces or even eliminates the likelihood of a Presidential veto of any Congressional action to repeal Section 1502 of the Dodd-Frank Act and the SECs conflict minerals…
UK Modern Slavery Act — Let The Posting Begin
Many organizations started voluntarily posting their modern slavery and human trafficking statements months ago. But now, the Modern Slavery Act’s transition period is over, and there are real deadlines to meet. Covered companies with financial years ending 31 March 2016 must post statements as soon as reasonably practicable but within six months of their financial year end. …
Budgeting for Conflict Minerals Compliance: Apps and Platforms — Is That All I Need?
As we approach the end of conflict minerals compliance year 4 (with 3 years of reports behind us), companies are budgeting for how they will address conflict minerals in 2017. Since the SEC rule took effect, supply chain professionals and in-house lawyers have found that compliance is complicated, time-consuming, and still changing because of the…
SEC Conflict Minerals Rule Legal Challenge is Over – But Not For Good
What Just Happened?
April 7, 2016 was the deadline for filing a petition for writ of certiorari to the US Supreme Court seeking a review of the court of appeals’ decision on the conflict minerals rule. The SEC did not file the petition, and Amnesty International (the intervenor in the case) did not make the…
UK Modern Slavery Act 2015 – 2 Weeks Notice
If your organization has a financial year-end of March 31, 2016 and is covered by the UK Modern Slavery Act 2015 (MSA), yours is in the first wave of MSA statements (MSA Statements) that must be published. The MSA Statement will set out what steps your organization has taken during the financial year to ensure…
EU Conflict Minerals Regulation — What’s Going On?
Many of you are asking what is happening with the EU conflict minerals regulation, what is the likely timing for adopting the regulation, and what should you do now to prepare.
Process — The development of the EU conflict minerals regulation has now entered the final negotiation phase. This phase, known as the “trialogue negotiations,” involves informal meetings between the…
Cobalt and Conflict Minerals — 3TG and C?
Companies and industry groups have been working for over 3 years on investigation and due diligence processes to determine the source and chain of custody of the tin, tantalum, tungsten and gold (3TG) in their products. But, there could now be pressure to add to the list of conflict minerals. Compliance Week raised this question last week in…
Slavery and Human Trafficking — How to Build Your Compliance Program
The California Transparency in Supply Chains Act of 2012 (“California Act”) applies to retailers and manufacturers with annual worldwide gross receipts over $100 million that are doing business in California. Those entities are required to disclose (by statements posted on their websites) their efforts to eradicate slavery and human trafficking from their direct supply chains…