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!"