Tag Archives: conflict-free

Conflict Minerals Decision – Now What?

Since December 2014, the U.S. Court of Appeals for the District of Columbia Circuit has been considering (again) the decision it reached previously about the constitutionality of the Conflict Minerals Rule. In an August 18, 2015 order, the Court of Appeals confirmed its earlier ruling that the Conflict Minerals Rule violates the First Amendment to … Continue Reading

Conflict Minerals Rule and Recycling Businesses

For purposes of the conflict minerals rule, conflict minerals that are sourced from recycled or scrap materials are deemed to be “DRC conflict free” and require disclosure only about the inquiry that led the reporting company to conclude that they were from those recycled or scrap sources.  That means that for products whose conflict minerals … Continue Reading

Legal Challenge — Review of the Docket — “Not Conflict Free” Product Description Requirement Violates First Amendment

As you recall, shortly after the SEC issued the Conflict Minerals Rule, several trade groups challenged the rule in federal court. The trade groups challenged the SECs cost-benefit analysis, questioned the SECs discretionary choices, and claimed that certain requirements in the rule violate the First Amendment.  Today, in a 2-1 decision, the D.C. Court of Appeals sided with the … Continue Reading
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