• Conflict Minerals Disclosures: Time for Final Preparations
  • March 25, 2014 | Authors: David S. Bakst; Harry R. Beaudry; John P. Berkery; Edward S. Best; Bernd Bohr
  • Law Firms: Mayer Brown LLP - New York Office ; Mayer Brown LLP - Houston Office ; Mayer Brown LLP - New York Office ; Mayer Brown LLP - Chicago Office ; Mayer Brown LLP - London Office
  • 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.”