Archives: Resources and Tools

Subscribe to Resources and Tools RSS Feed

Resource Extraction Payment Disclosure Rule — You Have More Time To Comment

In a January 21, 2016 release titled Extension of Comment Period for Disclosure of Payments by Resource Extraction Issuers, the Securities and Exchange Commission extended the comment periods for the revised proposed Rule 13q-1 (and the related amendment to Form SD).  That proposed rule relates to the disclosure of payments by resource extraction issuers in connection with the commercial development of … Continue Reading

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 … Continue Reading

Conflict Minerals — For European Companies That Haven’t Started The Process, Here’s How To Build Your Compliance Program

When the US Securities and Exchange Commission’s conflict minerals rule was issued in 2012, US reporting companies (and their suppliers) developed and implemented conflict minerals compliance programs. Companies have continued to enhance and beef up their programs since then. Now, companies should be supplementing their compliance programs to be ready to address the requirements of … Continue Reading

EU’s Proposed Regulation on Conflict Minerals – Part II

Editors Note: A prior version of this blog post incorrectly attributed the sentence in bold below. We sincerely apologize for any confusion this may have caused. This version has now been corrected.  Views on the Draft Regulation The draft EU conflict minerals regulation is a voluntary system of certification, which covers imports of the minerals … Continue Reading

EU’s Proposed Regulation on Conflict Minerals – Part I

The European Union (EU) is considering legislation that would regulate the importation of conflict minerals into the EU. The European Commission announced its proposed regulation on March 5, 2014. The draft regulation contains proposals for a voluntary self-certification process for importers of conflict minerals (tin, tantalum, and tungsten and gold) into the EU from anywhere … Continue Reading

New Conflict Minerals FAQs — But Little New Guidance

On April 7, 2014, the SEC issued a second set of FAQs on the conflict minerals rule which is presented as Frequently Asked Questions 13-21. Most of the new FAQs provide guidance on the Independent Private Sector Audit (IPSA), which very few companies will be required to provide for this first reporting year.  But, a couple … Continue Reading

Squire Sanders to Participate in Law Seminars International’s SEC’s Conflict Minerals Rule Webinar

Squire Sanders is pleased to participate in Law Seminars International’s “SEC’s Conflict Minerals Rules – Impacts of the New Rule and Strategies for Compliance” webinar on August 27, 2013. The webinar is from 3:00 to 4:00 P.M. EDT. Partner Dynda A. Thomas, leader of the firm’s conflict minerals team, will be a member of the … Continue Reading

SEC’s Guidance on Conflict Minerals — Not Just the FAQs

In the last two weeks, there have been more than a few articles and law firm memos written on the SEC’s FAQs relating to the Conflict Minerals Rule. Many of the articles and memos recite the FAQs. Others provide a brief discussion of them. Most are calling the FAQs the only guidance from the SEC since the Release last August. But, a … Continue Reading

Conflict Minerals – MetalMiner’s Guide to Manufacturers

MetalMiner recently published a white paper that offers some practical insights to manufacturers, especially about the materials and metals themselves. The white paper is titled The Definitive Guide to Conflict Minerals Compliance for Manufacturers and will be of particular interest to procurement officers, engineering and R&D groups that may be part of your conflict minerals compliance … Continue Reading

Popular Conflict Minerals Reference Materials and Tools

Even before our blog was introduced last week, clients and friends were using reference materials and resources we posted or developed since the Conflict Minerals Rule was issued in August of 2012. Here are several of the most widely used reference materials and resources. We are making them available so that you can use them as you develop your own policies and procedures: A … Continue Reading

New Squire Sanders SEC Conflict Minerals Interactive Flowchart

Squire Sanders has developed an interactive tool to help reporting companies work through the SEC’s conflict minerals rule. In its Release, the SEC provided a flowchart that was intended as an overall guide to compliance with the rule. Squire Sanders developed an extensive annotation of the flowchart and the key terms of the rule, and … Continue Reading
LexBlog