On August 22, 2012, the SEC promulgated the long-awaited Conflict Minerals Rule. The Conflict Minerals Rule requires any reporting company having conflict minerals that are necessary to the functionality or production of a product manufactured or contracted to be manufactured by that reporting company to file a report with the SEC on Form SD, disclosing whether those conflict minerals originated in a covered country, whether those conflict minerals came from recycled or scrap sources, and the activities performed to reach those conclusions. On November 13, 2012, the day the Conflict Minerals Rule became effective, the SEC published its small entity compliance guide for the Conflict Minerals Rule.

This step simply fulfills the SEC’s obligation to publish a small entity compliance guide to assist small entities with the Rule. The SEC has not provided additional guidance nor has it made changes to the Rule since the August 2012 Release. Included is a summary of the small entity compliance guide as well as information about the Squire Sanders interactive SEC Conflict Minerals Flowchart, which will further assist small entities in complying with the Rule.