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Dec 19, 2012

All that Glitters… May Be a Reportable Conflict Mineral!

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The first reporting period for the U.S. Securities and Exchange Commission’s new Conflict Minerals Rules begins on January 1st. Under the new rules, SEC reporting companies that manufacture products that contain tantalum, tin, tungsten or gold face new reporting requirements. Those companies will be seeking information from private companies in their supply chains. Required by the Dodd-Frank Act, the Conflict Minerals Rules require disclosure of products that contain conflict minerals originating in the Democratic Republic of the Congo and adjoining countries. SEC reporting companies have been working to put in place controls and procedures to comply with the Conflict Minerals Rules and to ensure that minerals contained in their products are conflict-free.

This Client Publication seeks to provide guidance, as well as to suggest some best practices for compliance. Our primary focus in this series of frequently asked questions is on how to get started, including:

  • analyzing whether the Conflict Minerals Rules apply to your company,
  • what is required by the “reasonable country of origin inquiry”, and
  • practical considerations for implementing a compliance framework.

View full memo, "All that Glitters… May Be a Reportable Conflict Mineral!"

Authors and Contributors

Jacques McChesney

Partner

Capital Markets

+44 20 7655 5791

+44 20 7655 5791

London

David Dixter

Partner

Capital Markets

+44 20 7655 5633

+44 20 7655 5633

London

Jonathan Handyside

Counsel

Capital Markets

+44 20 7655 5021

+44 20 7655 5021

London

Sami Toutounji

Partner

Compensation, Governance & ERISA

+33 1 53 89 70 62

+33 1 53 89 70 62

Paris

Domenico Fanuele

Partner

Capital Markets

+39 06 697 679 210

+39 06 697 679 210

Rome

Lisa Jacobs

Partner

Capital Markets

+1 212 848 7678

+1 212 848 7678

New York

Manuel A. Orillac

Partner

Capital Markets

+1 212 848 5351

+1 212 848 5351

New York

Antonia E. Stolper

Partner

Capital Markets

+1 212 848 5009

+1 212 848 5009

New York

Cynthia Urda Kassis

Partner

Project Development & Finance

+1 212 848 7969

+1 212 848 7969

New York

Robert Ellison

Partner

Capital Markets

+55 11 3702 2220

+55 11 3702 2220

São Paulo

Jason Lehner

Partner

Capital Markets

+1 416 360 2974

+1 416 360 2974

Toronto

Matthew Bersani

Partner

Capital Markets

+852 2978 8096

+852 2978 8096

Hong Kong

Kyungwon (Won) Lee

Partner

Capital Markets

+1 212 848 8078

+1 212 848 8078

New York

Andrew Schleider

Partner

Capital Markets

+65 6230 3882

+65 6230 3882

Singapore

Masahisa Ikeda

Partner

Capital Markets

+1 212 848 5378

+1 212 848 5378

New York