Compliance with the SEC's Conflict Minerals Rule
A little more than two years ago, “conflict minerals” were certainly well-known in humanitarian circles, but had not yet caught on handily as a “cause” within the public capital markets, not to mention mainstream industry and the broader supply chain. Enter the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act, and “conflict minerals” has become a household word, often holding far less favor than the intended humanitarian goal to put a squeeze on the flow of funds to militant groups in the Congo and adjoining countries (DRC).
Securities and Exchange Commission (SEC) issuers are forming highlevel internal compliance teams with representatives from legal, finance, internal audit and purchasing involved to assess the extent, if any, that the company’s products contain conflict minerals within the ambit of Rule 13p-1 under the Securities Exchange Act of 1934, adopted last August under Section 1502 of the Dodd-Frank Act. Diligence efforts are not confined to SEC issuers, however, with supply chain participants deeply involved in determining and certifying the original source of supplies of tantalum, tin, tungsten and gold (3TGs), and their numerous derivatives, sold to their customers.
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