March 13, 2015 – March 20, 2015
The summaries provided in this Weekly Recap do not necessarily represent the views of Squire Patton Boggs (US) LLP and should not be deemed to be endorsements of them. The Recap is intended to be a compilation of articles and events to encourage discussion within the conflict minerals community and to keep our readers updated on the most recent developments.


Elm Sustainability Partners Meets with Conflict Minerals SEC Staff

Elm Sustainability Partners met with the SEC staff responsible for conflict minerals disclosure requirements earlier this month and provided a recap of its meeting in its article titled SEC Staff Updates Elm on Conflict Minerals Disclosures.

The meeting addressed the following:

  • Last year, the SEC staff noted that some issuers conflated their reasonable country-of-origin inquiry (RCOI) with the due diligence requirements, as reported by Bloomberg BNA. Elm reports that “[t]he Staff clarified that the comments were aimed at Form SD filers only.”
  • The SEC staff noted that we can expect another round of Conflict Minerals FAQs of approximately 10 questions, but did not provide any indication of timing. The previous conflict minerals FAQs can be found here.
  • The SEC staff confirmed its position described in the Keller & Heckman LLP June 2014 letter regarding the treatment of chemical compounds under the conflict minerals rule.

For more insight, see the Elm article titled SEC Staff Updates Elm on Conflict Minerals Disclosures.

Fast Company Highlights Intel’s Drive to Make World’s First Microprocessor Conflict Free,  Goal to Make Entire Product Line Conflict-Free in 2016

In 2014, Intel Corporation announced that it had built the world’s first microprocessor entirely from conflict-free minerals. Next year, Intel’s goal is for all of its products to be conflict-free.

Fast Company, in its April 2015 issue, recently highlighted Intel’s drive to make the world’s first conflict-free microprocessor and its goal to make its entire product line conflict-free in 2016 in its article titled Intel’s Carolyn Duran Has a New Way of Avoiding Conflict at Work.

Fast Company noted that Carolyn Duran, Intel’s Supply Chain Director, “visited 91 smelters in 21 countries, using Intel’s purchasing power to put pressure on smelters…” Duran stated, “We ask for due diligence to not only understand where the material came from, but also that it’s not inadvertently or directly funding conflict.”