On August 22, 2012, the Securities and Exchange Commission issued a final rule covering corporate disclosures with regard to the use of conflict minerals. Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act had directed the SEC to issue rules defining specific disclosure requirements for companies for which conflict minerals are necessary to the functionality or production of a product manufactured, or contracted to be manufactured, by that company. Conflict minerals consist of columbite-tantalite (tantalum), wolframite (tungsten), cassiterite (tin), and gold. Section 1502 was intended to address concerns that the sourcing of certain minerals is supporting the ongoing conflict in the Democratic Republic of Congo ("DRC"). Conflict minerals are widely used by a large number of industries and many companies are now seeking to determine if the rule applies to their specific operations and, if so, what is expected in terms of compliance.
This program is intended to provide companies with both a high-level understanding of the rule and specific practical guidance on compliance requirements. The presentation will address key questions raised by the rule including what it means to contract for manufacture, what types of due diligence must be performed, and what must ultimately be disclosed. The program will also discuss several specific industry efforts to address the new conflict minerals rule. The program will:
o Provide an overall summary of the rule, including its background and key requirements
o Provide an in-depth discussion of the applicability of the rule to companies that either manufacture, or contract for the manufacture of, specific goods
o Describe what is expected in terms of due diligence on corporate supply chains
o Describe what is expected in terms of corporate disclosures
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