The EU Conflict Minerals Regulation (“EU Regulation”) is aimed at reducing the financing of armed conflicts through the trade of valuable minerals. But, before the EU Regulation went into full effect on 1 January 2021, the UK completed its separation
Conflict Minerals Law
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US SEC Conflict Minerals Reporting 2022 – Survey of the most recent “Actions taken and to be taken to improve due diligence”
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…
The EU Conflict Minerals Regulation and the Labyrinth of Brexit
The initial provisions of Regulation (EU) 2017/821 of the European Parliament and of the Council laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas…
Recent Climate and ESG Disclosure Activity — What does it mean for the SEC’s Conflict Minerals Rule?
In its first two months, the Biden Administration has given significant attention to climate-related and environmental, social, and governance (ESG) disclosure issues.
- February 1, 2021 — The SEC announced the appointment of Satyam Khanna as the Senior Policy Advisor for
…
EU Conflict Minerals Regulation — OECD Guidance Workshops
Now that the EU Conflict Minerals Regulation (EU Regulation) is in full effect, EU importers of tin, tantalum, tungsten, and gold and derivative products need to determine whether they are covered by the EU Regulation. Those EU importers that are…
OECD Due Diligence Guidance — Workshops
If you are an EU importer of tin, tantalum, tungsten or gold (3TG) covered by the EU Conflict Minerals Regulation, as of 1 January your due diligence process must comply with the OECD Due Diligence Guidance. Non-compliance may have…
Department of Labor’s “Do-Good” Investing Rule — Biden Administration Review
In yesterday’s post, we said we expected that the Biden Administration would re-focus attention on the US conflict minerals rule. In a similar vein, by the end of Inauguration Day, the Biden Administration indicated that it wants a review of…
New Day for the US Conflict Minerals Rule
It’s Inauguration Day in the US, and it’s likely to be a new day for the US conflict minerals rule. Where have we been and where are we going?
2012 – 2016
Pursuant to Section 1502 of the Dodd-Frank Act…
Countdown to EU Conflict Minerals Regulation (7 Months)
In less than 7 months, the EU conflict minerals regulation will take full effect, and importers into the European Union of certain threshold amounts of tin, tantalum, tungsten and gold (3TG) and of metals containing 3TG will be subject to…
COVID-19 and Conflict Minerals
We have been following this year’s conflict minerals filings to determine whether reporting companies have highlighted any impact of the COVID-19 shut-downs on their conflict minerals due diligence measures or results.
Based on our review of the 320 filings through…