As we discussed in a previous post, early in 2019, some companies were expressing concern that, because of the impacts of the shut-downs associated with COVID-19, certain of their suppliers might not be able to provide responses to their conflict
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Impact of COVID-19 Shut Downs on Conflict Minerals Reporting
You will recall that on March 25, 2020, to address certain challenges created by COVID-19, the Securities and Exchange Commission (SEC) issued the Order that extended the filing periods for certain public company reporting obligations under the Securities Exchange Act.…
Form SD Conflict Minerals Report Filing Deadline Unchanged
As of March 26, 2020, the filing deadline for Form SD’s is unchanged from the May 31 deadline included in the text of the Conflict Minerals Rule (and in the instructions to the Form SD). Note: because May 31, 2020…
EU Conflict Minerals Regulation Flowchart — Launching Today!
We are pleased to announce the launch of our EU Conflict Minerals Regulation Flowchart, which promises to be a valuable tool for those charged with compliance with the EU conflict minerals regulation.
In 2017, the EU adopted its…
EU Conflict Minerals Regulation – Step 1: Check Your Customs Declarations
While many companies are working to complete their due diligence and prepare conflict minerals disclosure for their SEC filings due May 31, others are considering whether they will be subject to the EU conflict minerals regulation when its due diligence and disclosure…
EU Conflict Minerals Regime
You’re no doubt working hard to complete your due diligence analysis and finalize your Form SD (and Conflict Minerals Report) as required by the US Conflict Minerals Rule. But, around the corner is another conflict minerals regime that could impact…
Costs of Conflict Minerals Compliance (1 of 3) – Why lower than expected?
The out-of-pocket costs of compliance with the SEC conflict minerals rule have been lower than those originally estimated by industry and by the SEC. But, it’s not because the original estimates were over-stated or inflated. And, these lower than expected out-of-pocket…
Financial CHOICE Act Passes in the House — Would Repeal SEC Conflict Minerals Rule
Today, on June 8, 2017, the US House of Representatives passed the Financial CHOICE Act by a vote of 233 to 186. The bill was sponsored by House Financial Services Committee Chairman Jeb Hensarling (R-Texas). The headline of the bill…
EU Conflict Minerals Regulation — Finally Published in the Official Journal!
At long last, the EU Conflict Minerals Regulation was published today in the Official Journal of the European Union. The EU Conflict Minerals Regulation 2017 (as published) will enter into force 20 days after publication (June 8, 2017) and take effect…
Conflict Minerals Rule — Will It Stay or Will It Go?
With only 19 days left before the SECs Form SD filing deadline, there is still a lot of talk about consequences of the SECs April 7, 2017 Statement (“April 2017 Statement”). In that statement, the SEC staff indicated that it would…