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Resource Centers

Conflict Minerals Resource Center

October 2014


On August 22, 2012, the U.S. Securities and Exchange Commission adopted Rule 13p-1 under the Exchange Act, which is known as the “Conflict Minerals Rule.” The first compliance period under the Rule began on January 1, 2013. Under the Rule, if conflict minerals — tin, tantalum, tungsten and gold — are necessary to the functionality or production of products manufactured or contracted to be manufactured by an SEC reporting company, the company must take steps to determine and make specified disclosures concerning, among other things, the source of the 3TG contained in its in-scope products. The intent of the Rule is to reduce a significant source of funding for armed groups that are committing human rights abuses and contributing to the conflict in the eastern DRC.

Although private companies are not directly subject to the Rule, to the extent that they are part of a public company’s supply chain, they will need to follow many of the same compliance procedures as public companies.

SRZ is a leader in Conflict Minerals Rule compliance. We are actively advising public and private companies and trade associations across a wide range of industries on compliance with the Rule. As part of our leadership in this area, we have developed this Conflict Minerals Resource Center. The Resource Center is continuously updated to reflect new developments and resources available to help public and private companies comply with the Rule.

We also are the only law firm with an Advanced Conflict Minerals Rule Compliance webinar series. This ongoing series features third-party experts and thought-leaders from across the compliance spectrum, including from the upstream, downstream, trade association, NGO, governmental and investor communities.

SRZ Authored Resources
The Legal Challenge to the SEC's Conflict Minerals Rule
SEC Resources (Includes Final Rules Adopted by the SEC)
State Department and Other U.S. Government Resources
OECD Resources
Industry Group Resources
Audit Resources
Selected Form Documents
NGO and UN Resources
State and Local Materials
Other Resources
Non-US Initiatives
Other Supply Chain Disclosure Initiatives
SRZ in the News

NEW SRZ and Conflict-Free Sourcing Initiative White Paper: Conflict Minerals Reporting: A Review of Calendar Year 2013 Filings and Recommendations for Calendar Year 2014 Compliance

SRZ Client Alert: Additional Supply Chain Disclosures by U.S. Public Companies Proposed

SRZ Client Alert: Breaking News — Motion to Stay Conflict Minerals Rule Denied — June 2 Filing Deadline Remains In Effect

SRZ Client Alert: SEC Publishes Statement on Conflict Minerals Reporting – Important New Guidance on Timing, Product Labeling and Audit Requirements

SRZ Client Alert: Appellate Court Issues Opinion on Conflict Minerals Rule — Portions of District Court Decision Affirmed and Portions Reversed

SRZ Client Alert: SEC Releases Additional Conflict Minerals FAQs — An Overview for Issuers and Audit Professionals

SRZ White Paper: Conflict Minerals Compliance: Observations and Recommendations for 2014 and Beyond

SRZ Client Alert: European Commission Proposes EU Conflict Minerals Legislation — Takeaways for U.S. Registrants and Other Companies

Practical Law Company: Conflict Minerals Diligence

Practical Law Company: Preparing for Conflict Minerals Rule Compliance: Company Action Items Checklist

Practical Law Company: Conflict Minerals Compliance: Observations and Recommendations for 2014 and Beyond

SRZ Client Alert: The AICPA’s Recent Conflict Minerals Guidance — An Overview for Public Companies

The Complete Compliance and Ethics Manual: Complying with the SEC’s New Conflict Minerals Rule: An Overview for Compliance Professionals

Mining, People and the Environment: Rule of Law: The New Conflict Minerals Rule Affects Mining and Metals Companies Across the World

Conflict Minerals Rule Decision Appealed — What Does This Mean for Your Compliance Program?

SRZ Client Alert: Court Upholds Conflict Minerals Rule — Is Your Compliance Program on Track?

SRZ Client Alert: SEC Publishes Conflict Minerals FAQs

SRZ Client Alert: Is Conflict Minerals Regulation Going International? New Developments in Canada and the EU

SRZ White Paper: Ramping Up Conflict Minerals Rule Compliance — A Near-Term Checklist for Public and Private Companies

SRZ Client Alert: Conflict Minerals Rule Challenged in Court — What Should Public and Private Companies Do Now? Near-Term Action Items in Today’s Uncertain Regulatory Environment

Practical Law Company: Conflict Minerals Rule Compliance Resources

SRZ Client Alert: SEC’s Conflict Minerals Rule Challenged in Court

Diamond District Monthly: Conflict Minerals Rule Adopted: Compliance Considerations for Privately Owned Companies in the Jewelry Industry

IR Magazine: What IR Departments Need to Know About the SEC’s Conflict Minerals Rule

SRZ Client Alert: The New Conflict Minerals Rule: An Overview for Private Equity and Venture Capital Professionals

SRZ Client Alert: SEC Adopts Final Conflict Minerals Rule: An Overview of the Rule, Action Items and Resources for Compliance

Diamond District Monthly: The SEC's Conflict Minerals Rule — An Overview for Companies in the Jewelry Industry

Marcum News & Events: The SEC's Conflict Minerals Rule — An Overview for Public and Private Companies

SRZ Advanced Conflict Minerals Rule Compliance Webinar Series

NEW
The Findings of Tulane University's DF S1502 Post-Filing Survey: Take-Aways for Issuers
Webinar | Slides

Integrating OFAC and FCPA Compliance with Your Conflict Minerals Compliance Program — Strategies for Mitigating Risk
Webinar | Slides | Resources

The EU’s Responsible Trading Strategy for Minerals from Conflict Zones
Webinar | Slides | Resources

An Update on the Conflict-Free Sourcing Initiative of the EICC and GeSI
Webinar | Slides | Resources

The New Conflict Minerals Reporting Template, Version 3.0
Webinar | Slides | Resources

IPC's New Conflict Minerals Data Exchange Standard
Webinar | Slides | Resources

Is Your Tin, Tantalum and Tungsten Conflict Free? An Overview of the iTSCi Conflict Minerals Project
Webinar | Slides

Dodd-Frank Section 1502: Perspectives From the U.S. GAO
Webinar | Slides

Expectations for Companies’ Conflict Minerals Reporting — The Recent Enough Project and Responsible Sourcing Network White Paper
Webinar | Slides

Downstream Due Diligence: Practical Application of the OECD Framework
Webinar | Slides

The Public-Private Alliance for Responsible Minerals Trade — An Overview for Downstream Companies
Webinar | Slides

The World Gold Council’s Conflict-Free Gold Standard: A Primer for Downstream and Upstream Companies
Webinar | Slides

Upstream Conflict Free Sourcing Initiatives: What You Need to Know as a Downstream Company
Webinar | Slides

Conflict Minerals: Meeting NGO and Investor Expectations
Webinar | Slides

IPC’s Conflict Minerals Data Exchange Standard
Webinar | Slides

IPC’s Conflict Minerals Due Diligence Guide
Webinar | Slides

Industry Solutions for Conflict Minerals Rule Compliance — AIAG Speaks
Webinar | Slides

OECD Due Diligence Guidance and Final Report on Pilot Implementation
Webinar | Slides

An Overview of the EICC and GeSi Conflict Minerals Reporting Template & Dashboard and Conflict Free Smelter Program
Webinar | Slides

Other SRZ Conflict Minerals Webinars

Action Items for Developing the Conflict Minerals Compliance Program
Webinar | Slides

Conflict Minerals: Industry Veterans Speak Out on the Changing Requirements of Due Diligence
Webinar

Conflict Minerals: Demystifying Form SD
Webinar | Slides

National Association of Manufacturers, Chamber of Commerce of the United States of America, Business Roundtable v. United States Securities and Exchange Commission

Documents Filed in the U.S. Court of Appeals for the District of Columbia

Certificate Listing and Describing the Record Before the Securities and Exchange Commission

Industry Coalition Amici Brief in Support of Petitioners

Brief of Amici Curiae Global Witness and Former Members of The United Nations Group of Experts on the Democratic Republic of The Congo in Support of Respondent

Amicus Brief for Respondent Filed by Twelve Current and Former Members of Congress

Amicus Brief for Respondent Filed by Better Markets, Inc. 

Deferred Joint Appendix

Intervenor for Respondent, Final Brief Filed by Amnesty International

Final Opening Brief of the Petitioners

Final Reply Brief of the Petitioners

Final Reply Brief of the Securities and Exchange Commission, Respondent

Petitioners' Motion to Transfer and for Leave to File Under Circuit
Rule 27(g)


Per Curiam Order Granting Petitioners' Motion to Transfer Case to the USDC District of Columbia

Letter Sent to Transfer Case to USDC District of Columbia

Documents Filed in the District Court After Transfer from the Court of Appeals

Memorandum Opinion Denying Plaintiffs' Motion for Summary Judgment

Court’s Order re: Plaintiffs’ Motion for Summary Judgment and Defendants’ Cross-Motion for Summary Judgment

Documents Filed in the U.S. Court of Appeals for the D.C. Circuit After Memorandum Opinion Denying Plaintiff's Motion for Summary Judgment

Plaintiff's Notice of Appeal at the U.S. Court of Appeals for the D.C. Circuit

Clerk’s Scheduling Order

Appellant’s Motion to Expedite, with Consents from the SEC and Intervenors

Order Setting Briefing Schedule

Notice of Constitutional Challenge, Filed by Appellants

Appellants’ Preliminary Statement of Issues

Certificate as to Parties, Rulings and Related Cases

Opening Brief of Appellants

Representation of Parties’ Consent to Participation as Amici Curiae

Notice of Consent of the Parties to the Participation of Experts on the Democratic Republic of the Congo as Amicus Curiae

Notice of Consent of the Parties to the Participation of American Petroleum Institute as Amicus Curiae on Behalf of the Appellants

Brief of the Retail Litigation Center, Inc. and the National Retail Federation as Amici Curiae in Support of Appellants

Industry Coalition Amici Brief in Support of Appellants

Brief of Amicus Curiae Experts on the Democratic Republic of the Congo in Support of Petitioners

Brief of American Petroleum Institute as Amicus Curiae on Behalf of Appellants and Supporting Reversal of the District Court's Order

Notice of Intent to File Amici Brief in Support of Appellants by American Coatings Association, American Chemical Council, Can Manufacturers Institute, The Society of the Plastics Industry, Inc.

Brief of the Securities and Exchange Commission, Appellee

Consent by All Parties for Global Witness and Former Members of the United Nations Group of Experts on the Democratic Republic of the Congo to file Amici Curiae Brief in Support of Respondent

Representation of the Consent of All Parties and Intervenors for Better Markets, Inc. to File an Amicus Curiae Brief in Support of Appellee

Notice of Intent to File as Amici Curiae by Current and Former Members of Congress

Brief of Senator Durbin, Congressman McDermott, et al. as Amici Curiae in Support of Appellee

Brief of Amici Curiae Global Witness and Former Members of the UN Group of Experts on the Democratic Republic of the Congo in Support of Appellee

Response Brief of Amnesty International of the USA, Inc. and Amnesty International Ltd.

Brief of Better Markets, Inc. as Amici Curiae in Support of Appellee and Affirmance of the District Court’s Order

Order Scheduling Oral Argument on January 7, 2014 before Judges Srinivasan, Sentelle and Randolph

Appellant Reply Brief Filed by Business Roundtable, Chamber of Commerce of the United Stated of America and National Association of Manufacturers

Letter Filed by SEC Advising of Additional Authorities

Letter Filed by Business Roundtable, Chamber of Commerce and National Association of Manufacturers Advising of Additional Authorities

The Court’s Opinion on National Association of Manufacturers v SEC

Documents Filed Regarding Proposed Stay of the Rule

Denial of Appellants’ Emergency Motion for Stay of the Rule

Appellants’ Reply in Support of Emergency Motion for Stay of the Rule

SEC Response in Opposition to Appellants’ Motion for a Full Stay of the Rule

Amnesty International Response in Opposition to Stay of the Rule

Industry Coalition Amici Statement in Support of Appellants’ Emergency Motion for Stay

Order to Adopt Appellants’ Proposed Briefing Schedule

Appellants’ Emergency Motion for Stay of the SEC’s Conflict Minerals Rule in the U.S. Court of Appeals-D.C. Circuit

Petitioners’ Motion for a Stay of the Rule

Petitions for Rehearing

NEW
Joint Response by the National Association of Manufacturers, Chamber of Commerce and Business Roundtable to the Petitions for Rehearing En Banc

Order for Appellants to File a Joint Response

Supplemental Brief by Amnesty International of the USA and Amnesty International Limited in Support of Petition for Panel Rehearing and Rehearing En Banc

Petition by Appellees Amnesty International Limited and Amnesty International USA for Rehearing, for Rehearing En Banc

Petition by Appellee SEC for Rehearing, for Rehearing En Banc

Other Sources

Court’s Opinion on American Meat Institute v. U.S. Department of Agriculture

Global Witness — Gutless Companies Launch Lawsuit to Avoid Coming Clean on Conflict Minerals

Global Witness — Companies Must Take Clear Position on Legal Threat to Conflict Minerals Provision

Global Witness — Companies Must Come Clean on Conflict Minerals Lawsuit

Resource Extraction Rule Litigation

The Court's Memorandum Opinion on API v. SEC

SEC Order for Partial Stay of Conflict Minerals Rules

Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule

April 28, 2014 Joint Statement from Commissioners Gallagher and Piwowar on the Conflict Minerals Decision

Form SD

SEC Frequently Asked Questions on Conflict Minerals

SEC Adopts Final Rules on Conflict Minerals

SEC Press Release — SEC Adopts Rule for Disclosing Use of Conflict Minerals, 8/22/12

SEC Open Meeting Statement by Chairman Mary L. Schapiro

SEC Conflict Minerals Open Meeting Statement by Commissioner Troy A. Paredes

SEC Open Meeting Statement by Commissioner Luis A. Aguilar

SEC Open Meeting Statement by Commissioner Daniel M. Gallagher

SEC Open Meeting Statement by Commissioner Elisse B. Walter

SEC’s Division of Corporation Finance Conflict Minerals Disclosure — A Small Entity Compliance Guide

SEC Proposed Release on Conflict Minerals

SEC Transcript of Roundtable on Conflict Minerals

Congress

Congressional Research Service: Conflict Minerals in Central Africa — U.S. and International Responses

May 21, 2013, Monetary Policy and Trade Subcommittee Hearing on “The Unintended Consequences of Dodd-Frank’s Conflict Minerals Provision”

U.S. Government Accountability Office

GAO — Stakeholder Options for Responsible Sourcing Are Expanding, But More Information on Smelters Is Needed

GAO — Conflict Minerals Disclosure Rule: SEC's Actions and Stakeholder-Developed Initiatives

GAO — Government Auditing Standards

GAO — SEC Conflict Minerals Rule — Information on Responsible Sourcing and Companies Affected

U.S. Department of State

U.S.-Africa Roundtable on Responsible Minerals Sourcing in Africa: Remarks

Statement Concerning the Continued Importance of Due Diligence for Conflict Minerals

State Department Statement Concerning Implementation of Section 1502 of the Dodd-Frank Legislation Concerning Conflict Minerals Due Diligence

Statement Concerning Continued Implementation of Conflict Minerals Due Diligence Pursuant to Section 1502 of the Dodd-Frank Act

U.S. Department of Commerce

NEW List of Conflict Minerals Processing Facilities Worldwide

Other U.S. Government Resources

Public-Private Alliance for Responsible Minerals Trade Memorandum of Understanding

Public-Private Alliance for Responsible Minerals Trade Draft Work Plan

USAID Minerals & Conflict — A Toolkit for Intervention

White House

Executive Order — Regarding the Democratic Republic of the Congo

Executive Order — 2006

Executive Order Fact Sheet


Communiqué by Participants at the 7th ICGLR-OECD-UN Group of Experts Forum on Responsible Mineral Supply Chains

OECD Due Diligence Guidance: Towards Conflict-Free Mineral Supply Chains

OECD Due Diligence Guidance Summer 2013 Training ‌Webinars

OECD Risk Awareness Tool for Multinational Enterprises in Weak Governance Zones

OECD Conflict Minerals Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

OECD Gold Supplement to the Due Diligence Guidance

OECD Report — Downstream Pilot Implementation of the OECD Due Diligence Guidance, Baseline Report on the Supplement of Tin, Tantalum, and Tungsten

OECD Report — Downstream Pilot Implementation of the OECD Due Diligence Guidance, Cycle 2 Interim Progress Report

OECD Final Downstream Report on One-Year Pilot Implementation of the Supplement on Tin, Tantalum, and Tungsten

OECD Report — Upstream Pilot Implementation of the OECD Due Diligence Guidance, Baseline Report

OECD Report — Upstream Pilot Implementation of the OECD Due Diligence Guidance, Cycle 2 Interim Progress Report

Final Upstream Report on Implementation of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

OECD ICGLR-OECD-UN Meeting on Implementation of Due Diligence for Responsible Mineral Supply Chains

OECD Work on Conflict-Free Mineral Supply Chains & the U.S. Dodd-Frank Act

ICGLR: Mineral Supply Chain Due Diligence Audits and Risk Assessments in the Great Lakes Region

AIAG Resources

NEW New Conflict Minerals Microsites in English and Chinese Help Automotive Companies Connect with Resources to Meet SEC Requirements

AIAG Conflict Minerals Microsite: The Auto Industry and Conflict Minerals

AIAG Conflict Minerals Frequently Asked Questions

AIAG Conflict Minerals Reporting Checklist

AIAG/iPoint Conflict Minerals Platform

Case Study of Automakers and Supplier to Conflict Minerals Reporting

Conflict Minerals Compliance Reporting Process: A Collaborative Case Study

AIAG Secures Agreement from Multiple Automakers to Map the Supply Chain for the First Time

EICC and GeSI Resources

EICC and GeSI Conflict-Free Smelter Program: Compliant Smelter List

EICC and GeSI Conflict-Free Smelter Program: Smelter Introductory Training and Instruction Document

EICC-GeSI Conflict Free Smelter Assessment Program: Frequently Asked Questions

EICC and GeSI Conflict Minerals Reporting Template & Dashboard

EICC and GeSI Conflict Minerals Smelter Program: Audit Protocols & Procedures

EICC and GeSI Conflict Minerals: Conflict-Free Smelters & Refiners

EICC’s The Conflict-Free Sourcing Initiative — Reasonable Practices to Identify Sources of Conflict Minerals: Practical Guidance for Downstream Companies

Conflict-Free Smelter Program — Supply Chain Transparency Smelter Audit Protocol for Tungsten

Conflict-Free Smelter Program — Supply Chain Transparency Smelter Audit Procedure for Tungsten

Conflict-Free Smelter Program — Tungsten Smelter List

Tracing a Path Forward: A Study of the Challenges of the Supply Chain for Target Metals Used in Electronics

Frequently Asked Questions on Company Assurance and Conflict Minerals Disclosure

Triggers for Independent Private Sector Audit (IPSA) During the Temporary Period Where Products Are “DRC Conflict Undeterminable”

IPC Resources

IPC Conflict Minerals Resources for the Electronics Industry Main Page

IPC Draft Conflict Minerals Due Diligence Guideline

New IPC Guide Spells Out Electronics Manufacturers’ Conflict Minerals Due Diligence Obligations

iTSCi Resources

NEW Conflict Free Mines in the Kivu's Continue to Grow within iTSCi

NEW
Open Letter Discusses Impact of Dodd Frank

iTSCi Katanga Bi-Annual Report July - December 2013

iTSCi South Kivu Bi-Annual Report July - December 2013

iTSCi Rwanda Bi-Annual Report July - December 2013

iTSCi Maniema Bi-Annual Report July - December 2013

iTSCi Programme Extension to Burundi

iTSCi Governance Assessment: Rubaya, North Kivu

ITRI Tin Supply Chain Initiative

iTSCi Project Overview

London Bullion Market Association Resources

LBMA Third Party Audit Guidance

LBMA Responsible Gold Guidance

LBMA Responsible Gold Programme, Executive Summary

LBMA Responsible Gold: Role of the LBMA

LBMA Responsible Gold Programme Update, 9/11/2012

World Gold Council Resources

World Gold Council Conflict-Free Gold Standard

World Gold Council Conflict-Free Gold Standard: An Introduction

World Gold Council Conflict-Free Gold Standard Guidance for Assurance Providers

World Gold Council Conflict-Free Gold Standard Guidance for Implementing Companies October 2012

Other Industry Group Resources

Dubai Multi Commodities Centre — Practical Guidance for Market Participants in the Gold and Precious Metals Industry

EITI Business Guide: How Companies Can Support Implementation

Gold Organizations to Recognize Each Other’s Conflict Audits

International Council on Mining & Metals — Human Rights in the Mining & Metals Sector: Overview, Management Approach and Issues

IPIS Research — Interactive Map of Militarized Mining Areas in the Kivus

National Association of Manufacturers Conflict Minerals Main Page

Responsible Jewellery Council Chain-of-Custody Certification

Solutions Network: Conflict Free Tin Initiative


The Auditing Roundtable Guidance

AICPA Conflict Minerals Resources

AICPA Conflict Minerals Reports Q&A Part 1

AICPA Conflict Minerals Reports Q&A Part 2

AICPA Conflict Minerals Reports Q&A Part 3

AICPA Conflict Minerals Reports Q&A: Independence

AICPA Conflict Minerals: Independent Private Section Audit (IPSA) Independence Considerations

AICPA Conflict Minerals Nonaudit Services Independence Matrix

The Generally Accepted Government Auditing Standards (GAGAS) - also known as the Yellow Book



National Association of Manufacturers Supplier Notification Letter

IPC Dear Supplier Letter

IPC Dear Customer Letter

NGO Resources

Amnesty International — Profits and Loss: Mining and Human Rights in Katanga, Democratic Republic of the Congo

BGR (German Federal Institute for Geosciences and Natural Resources) — Certifying Natural Resources: A Comparative Study on Best Practice and Future Scenarios for the Certification of Trading Chains in Mineral Production

Enough Project — The Impact of Dodd-Frank and Conflict Minerals Reforms on Eastern Congo’s Conflict

Enough Project — Coming Clean: A Proposal for Getting Conflict Minerals Certification on Track

Enough Project — Striking Gold: How M23 and its Allies are Infiltrating Congo’s Gold Trade

Enough Project — From Child Miner to Jewelry Store: The Six Steps of Congo's Conflict Gold

Enough Project — Company Rankings on Conflict Minerals

Enough Project — Four Steps for the U.S. and U.N. to Defuse Congo's Escalating Crisis

Enough Project — The Recent Fighting in Eastern Congo and Its Implications for Peace

Enough Project — Expectations for Companies’ Conflict Minerals

Enough Project — Breaking the Links Between Natural Resources and Conflict: The Case for EU Regulation

ICGLR Regional Certification Mechanism (RCM) — Certification Manual

Global Witness Guide for Companies — Do No Harm: Excluding Conflict Minerals From the Supply Chain

Greening ICT Supply Chains — Survey on Conflict Minerals Due Diligence Initiatives

Raise Hope for Congo Conflict Minerals Company Rankings

Public-Private Alliance — Summary of In-Region Initiatives That Support Conflict-Free Minerals Sourcing

Report of the UN Group of Experts on the Democratic Republic of the Congo

Responsible Sourcing Network — What's Needed: An Overview of Multi-Stakeholder and Industry Activities to Achieve Conflict-Free Minerals

Solutions for Hope Tantalum Sourcing Project: Platform to Support Responsible Sourcing, Peacebuilding and Community Development

The STAND Project — The Conflict-Free Canada Initiative

World Vision — Child Miners Speak: Key Findings in Child and Artisanal Mining in Kambove DRC

UN Resources

UN Global Compact Business Guide for Conflict Impact Assessment and Risk Management

UN Security Council Letter Dated 12 November 2012 Concerning the Democratic Republic of the Congo

Letter Dated 19 July 2013 from the Chair of the Security Council Committee Established Pursuant to Resolution 1533 (2004) Concerning the Democratic Republic of the Congo Addressed to the President of the Security Council

Final Report of the Group of Experts on the Democratic Republic of the Congo

Pittsburgh City Council Proclamation on Conflict Minerals

St. Petersburg City Council Resolution on Conflict Minerals

Text of California Senate Bill No. 861 on Conflict Minerals

Text of Maryland House Bill 425 on Conflict Minerals

Text of Proposed Massachusetts Bill H.2898 on Conflict Minerals

Text of Proposed Connecticut Bill No. 666 on  Conflict Minerals
 
Payson Center Conflict Minerals Survey

Payson Center Conflict Minerals Survey Protocol

Letter by Eleven Senators and House Members to the SEC

TheCorporateCounsel.net Survey Results: Conflict Minerals

Cheuvreux Credit Agricole Group Conflict Minerals Presentation, October 2012

Institute for Applied Ecology — Conflict Minerals — An Evaluation of the Dodd-Frank Act and Other Resource-Related Measures

Maps

State Department Conflict Minerals Map

IPIS: Conflict Mineral Mapping Eastern DRC

IPIS: Analysis of the Interactive Map of Artisanal Mining Areas in Eastern DRC

European Union

European Commission — Press Release: EU Proposes Responsible Trading Strategy for Minerals from Conflict Zones

European Commission — Frequently Asked Questions on Responsible Sourcing of Minerals from Conflict Zones

European Commission — Draft Regulation

European Commission — Joint Communication by the European Commission and the High Representative

European Commission — Commission Staff Working Document

European Commission — External Study

European Commission — Outcome of the Public Consultation

European Commission: Report on Promoting Development Through Responsible Business Practices

European Commission — Trade, Growth and Development: Tailoring Trade and Investment Policy for Those Countries Most in Need

European Commission — Public Consultation on a Possible EU Initiative on Conflict Minerals

European Commission – Specific Privacy Statement: Public Consultation on a Possible EU Initiative on Responsible Sourcing of Minerals Originating from Conflict-affected and High-Risk Areas Referred as "Consultation" in the Text

European Parliament Resolution with Provision on Conflict Minerals

Speech by Commissioner De Gucht at the BDI Event “Responsible Sourcing of Minerals from Conflict-Affected Regions”

United Kingdom

UK Department for Business Innovations and Skills – Corporate Responsibility – A Call for Views

United Kingdom Foreign and Commonwealth Office — Conflict Minerals: Guiding British Companies Trading in Minerals from the Democratic Republic of Congo to be Socially, Economically and Environmentally Responsible

Australia

Australian Government Due Diligence Guidelines for Responsible Supply Chains

Canada

NEW Proposed Conflict Minerals Act (Failed, September 24, 2014)

Text of Proposed Conflict Minerals Act

Text of California Transparency in Supply Chains Act

Press Release from Bill Sponsor on H.R. 2759, Business Transparency on Trafficking and Slavery Act (Pending)

Text of H.R. 2759 — Business Transparency on Trafficking and Slavery Act (Pending)

Text of H.R. 4842 — Business Supply Chain Transparency on Trafficking and Slavery Act of 2014


Supply Chains Could Be Weak Conflict Minerals Link,” Mining Journal, Sept. 26, 2014

Just Four Companies Had Conflict Mineral Reports Audited,” The Wall Street Journal – CFO Journal, Sept. 18, 2014

The Morning Risk Report: Conflict Minerals List Makes Compliance a Little Easier,” The Wall Street Journal – Risk & Compliance Journal, Sept. 9, 2014

The Potential Hidden Benefits of Conflict Minerals Disclosures,” Compliance Week, Sept. 9, 2014

Conflict Minerals Law Starts Working Despite Poor Industry Response,” Reuters, July 1, 2014

Conflict Minerals Disclosure Will Improve, Says Lawyer,” Mining Journal, June 4, 2014

Dozens of Firms Report N. Korea Gold in Supply Lines,” The Wall Street Journal – Risk & Compliance Journal, June 4, 2014

Conflict Mineral Filings To Draw Harsher Spotlight,” Law360, June 3, 2014

Future of Conflict Minerals Reports May Depend on Meat Labels,” CFO Journal, June 3, 2014

Companies to ‘Show Their Work and Not Their Answer’ in Conflict Minerals Reports,” Resource Investing News, May 23, 2014

The Final Stretch for Conflict Minerals Compliance,” Treasury & Risk, May 21, 2014

Companies Unearth Few Answers on ‘Conflict Minerals,’ “ CFO Journal, May 20, 2014

A Month Before Deadline, Firms Play for Time on Conflict-Mineral Reporting,” Bloomberg Businessweek, April 29, 2014

Conflicts Minerals Ruling Doesn’t Mean Companies Are Off the Hook,” Compliance Week, April 22, 2014

Advice for Companies After Conflict Minerals Ruling,” The FCPA Blog, April 17, 2014

Joining US, EC Moves on Conflict Minerals,” The American Lawyer, March 10, 2014

Conflict Minerals: Due Diligence, Disclosure Lessons for Compliance (Part 3),” The FCPA Blog, March 7, 2014

Conflict Minerals: Due Diligence, Disclosure Lessons for Compliance (Part 2),” The FCPA Blog, March 6, 2014

The Art of Conflict Minerals Compliance,” Inside Counsel, Jan. 28, 2014

Conflict Minerals Compliance: Observations and Recommendations for 2014 and Beyond,” Main Justice, Jan. 27, 2014

How Court Could Shape a New Conflict Minerals Rule,” Compliance Week, Jan. 22, 2014

7 Leading Industry Associations Join Forces To Launch The Single Largest Initiative To Help Address Conflict Minerals Compliance Questions,” 3BL Media, Jan. 22, 2014

Conflict Minerals Rules May Soon Have International Counterparts,” Compliance Week, Nov. 5, 2013

What’s in Your Smartphone? Blood Electronics,”  Politico, Oct. 24, 2013

SEC Weighs Conflict Minerals and Congressional Mandates,” Agenda, Oct. 21, 2013

SEC's Conflict Minerals Rule Win Means the Clock is Ticking,” Compliance Week, July 30, 2013

Court Upholds ‘Conflict Minerals’ Rule,” CFO.com, July 24, 2013

The Global Lawyer: Why Your Next iPhone Will be Blood-Free,” The Am Law Litigation Daily, July 24, 2013

Conflict Minerals Rules Stretch Supply Chain Software Capabilities,” CIO Journal, July 8, 2013

SEC Excludes Packaging From Conflict Minerals Testing,” CFO Journal, June 3, 2013

Showing Your Metal,” IR Update, May 2013

SRZ Law Firm Leads the Charge for Conflict Minerals Compliance,” 3BL Media, April 3, 2013

Conflict Minerals Showdown Heats Up,” ThomasNet Industry Market Trends, March 19, 2013

Time to Look at the Conflict Minerals Disclosure Requirements,” The D&O Diary, March 7, 2013

Shareholder Activists Push for Human Rights Committees,” Compliance Week, March 5, 2013

Conflict Mineral Reports Present Challenges for Auditors,” The Wall Street Journal Corruption Currents Blog, Jan. 29, 2013

Rocks and a Hard Place; Lawsuit Challenges SEC Disclosure Rule on Origins of Four 'Conflict Minerals,’” The National Law Journal, Jan. 28, 2013

Regulators Have Unfinished Business to Complete in 2013,” Compliance Week, Jan. 2, 2013

"Gut Check: A New SEC Rule Forces Companies to Plumb the Sources of Their Products," Corporate Counsel, Nov. 1, 2012

"Conflict Minerals Rule in Limbo, as Legal Challenge Awaits," Compliance Week, Oct. 30, 2012

"Business Groups File Challenge to SEC Conflict Minerals Rule," Corporate Counsel, Oct. 24, 2012

"Business Groups Sue to Block 'Conflict Minerals' Rules," The Wall Street Journal Corruption Currents Blog, Oct. 22, 2012

"Manufacturers Mount Legal Challenge to Conflict Minerals Rule," CFO Journal, Oct. 22, 2012

"Watch Conflict Minerals Rule, PE CCOs Warned," Compliance Intelligence, Oct. 22, 2012

"U.S. Chamber, NAM Take Legal Action Against Conflict Minerals Rule," Compliance Week, Oct. 22, 2012

"Dodd-Frank Opponents Consider New Legal Challenges," Compliance Week, Oct. 16, 2012

"Initial Reactions: Businesses Score on Conflict Minerals, Lose on Extractive Industry Disclosures," The Wall Street Journal, Sept. 22, 2012

"SEC's 'Conflict Minerals' Rules Open Companies to Activists," The Wall Street Journal, Sept. 19, 2012

"What IR Departments Need to Know About the SEC’s Conflict Minerals Rule," Inside Investor Relations, Sept. 17, 2012

"How Conflict Minerals Rules Affect Steel Scrap and Gold Supply Chains," MetalMiner, Sept. 5, 2012

"Schulte Roth & Zabel: Taking Action on the New Conflict Minerals Rule," Practising Law Institute - Securities Law Practice Center, Aug. 30, 2012

"High Tide: From Britain’s FATCA to Rejecting Tymoshenko’s Appeal," The Wall Street Journal, Aug. 29, 2012

"Conflicts Start Early on Minerals Rule; 'Absolutely Insane,'" Compliance Week, Aug. 28, 2012

"Conflict Minerals Action Items (Schulte Roth & Zabel)," Dodd-Frank Section 1502 Blog, Aug. 27, 2012

"SEC Rule Mandates Sourcing of 'Conflict Minerals' at U.S. Companies," Corporate Counsel, Aug. 24, 2012

"US Companies Face Tougher Rules on African War Zones," The Global Legal Post, Aug. 24, 2012

"Apple, Boeing Among Thousands Explaining Metal Origins to SEC," Bloomberg, Aug. 22, 2012

"SEC's Toned-Down Conflict Mineral Rule Still Faces A Fight," Law360, Aug. 22, 2012

"U.S. Oil and Mining Companies Must Disclose Payments to Foreign Governments," The New York Times, Aug. 22, 2012

"US SEC Forces Disclosure of Oil, Mining Payments Abroad," Trust Law, Aug. 22, 2012

"SEC Said Poised To Make Companies Report Business With Warlords," Bloomberg, July 25, 2012

SRZ offers a full-service capital markets practice that provides transactional and ongoing advice through all stages for companies of all sizes. We counsel public companies, their boards, board committees, special committees, executive officers and investors in connection with ongoing compliance under the U.S. securities laws, including under Dodd-Frank and Sarbanes-Oxley, and with exchange requirements, as well as on governance and executive compensation matters. We closely monitor and advise our public company clients on rule-making initiatives and evolving best practices.

We have experience in every major industry, including apparel, automotive, aviation, biotechnology, broadcasting, business services, computer hardware, consumer services, defense, energy, entertainment, financial services, food and beverage, government services, healthcare, information technology, insurance, manufacturing, media, natural resources, real estate, restaurant and hospitality, retailing, shipping and logistics, software, technology and telecommunications.


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From inception through filing and beyond, find out how SRZ can help you to efficiently establish and administer your Conflict Minerals Rule compliance program. For more information, please email Michael Littenberg at .