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
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
TheCorporateCounsel.net asked companies a few questions to determine how far along they are in the process of complying with the SEC’s new conflict minerals rule. Questions included: Who is responsible for conflict minerals compliance? Do you currently expect that you will be required to file a Form SD? If you manufacture or contract to manufacture … Continue Reading
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
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 … Continue Reading
