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Conflict Minerals Disclosures: Time for Final Preparations

by David S. Bakst
Mayer Brown LLP - New York Office

Harry R. Beaudry
Mayer Brown LLP - Houston Office

John P. Berkery
Mayer Brown LLP - New York Office

Edward S. Best
Mayer Brown LLP - Chicago Office

Bernd Bohr
Mayer Brown LLP - London Office

March 25, 2014

Previously published on March 24, 2014

The filing deadline is drawing near for the first conflict minerals disclosures required by the Dodd-Frank Wall Street Reform and Consumer Protection Act and the conflict minerals rule adopted by the US Securities and Exchange Commission (SEC). SEC reporting companies, regardless of their fiscal year, must file a report on new Form SD by Monday, June 2, 2014, if, during calendar year 2013, they used conflict minerals that were necessary to the functionality or production of a product they manufacture or contract to be manufactured. For a discussion of the requisite due diligence requirements and circumstances triggering conflict minerals disclosure requirements, including associated requirements for Conflict Minerals Report and an independent private sector audit, see our September 5, 2012 Legal update, “US Securities and Exchange Commission Adopts Final Conflict Minerals Disclosure Rule.”


The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.

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