It’s Inauguration Day in the US, and it’s likely to be a new day for the US conflict minerals rule. Where have we been and where are we going? 2012 – 2016 Pursuant to Section 1502 of the Dodd-Frank Act of 2010, the SEC issued its conflict minerals rule in 2012, requiring reporting companies to … Continue Reading
Today, April 3, 2017, the European Council took the last procedural step and approved the EU conflict minerals regulation. Publication in the Official Journal of the European Union will be the next and final step of the process. The publication could occur in 3 to 6 weeks. Here is the text of the official EU Conflict Minerals … Continue Reading
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
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
There has been a lot of discussion about the case against Costco relating to its California Transparency in Supply Chains Act disclosure. Here is the link to the post about the Costco case that I co-wrote for our Global Supply Chain Law Blog . This case is an example of how supply chain policy and disclosure can lead to litigation. … Continue Reading
