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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.  … Continue Reading

EU Conflict Minerals Regulation — Source Intelligence Webinar

Dynda Thomas will be participating in a Source Intelligence-hosted webinar titled “EU Conflict Minerals:  When, What and How to Comply.” She will discuss the key provisions and the status of the proposed EU regulation and how to build your compliance program so that you are ready when the regulation is adopted (likely later this year).  Other speakers include:  Leah … Continue Reading

Here We Go Again — New Proposed Resource Extraction Payment Rules

As we discussed in posts on September 3, 2015 and on October 2, 2015, Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act required the SEC to issue resource extraction payment rules.  The purpose of those rules was to promote the federal government’s desire for transparency about resource extraction payments made by commercial entities to governments around the world.   The initial … Continue Reading

Supply Chain Disclosure Risk 30-Minute Boot Camp — September 15

Those of you involved with conflict minerals compliance will want to consider how recent supply chain litigation relates to your conflict minerals policies and disclosures. In the last two posts in our Supply Chain Law blog (here  and here), we discussed the most recent supply chain litigation trend:  litigation based on companies’ California Transparency in Supply Chains Act disclosures.  … Continue Reading

FORM SD – EDGAR Filing Glitch — Conflict Minerals Report is “Exhibit 1.02”

The Division of Corporation Finance has confirmed that there is a glitch in the EDGAR filing system.  EDGAR is not accepting Exhibit 1.01 to the Form SD but is accepting Exhibit 1.02.  Therefore, despite the Instructions to the Form SD, you will need to refer to your Conflict Minerals Report as “Exhibit 1.02” in order for the filing … Continue Reading
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