July 14, 2020

Volume X, Number 196

July 13, 2020

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COVID-19 in Conflict Minerals Reports — Update

As we discussed in a previous post, early in 2019, some companies were expressing concern that, because of the impacts of the shut-downs associated with COVID-19, certain of their suppliers might not be able to provide responses to their conflict minerals inquiries in a timely manner.  They worried that their conflict minerals disclosures for calendar year 2019 could be less robust as a result.

As of May 13, 2020, based on our review, none of the Form SDs filed had referred to “COVID-19,” “coronavirus” or the “pandemic. Now, through the end of May 21, 2020, with 10 days left in the filing season for calendar year 2019, based on our review, five companies mentioned “COVID-19,” coronavirus” or the “pandemic” when explaining suppliers’ responses.

It is possible that the COVID-19 shut-down has impacted the quality and number of supplier responses to conflict minerals inquiries for other companies that have not included discussion that in their filings.

© Copyright 2020 Squire Patton Boggs (US) LLPNational Law Review, Volume X, Number 143

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About this Author

Dynda A. Thomas, SquirePattonBoggs, Mergers and Acquisitions Lawyer
Partner

Dynda Thomas has extensive experience in the areas of mergers and acquisitions and project finance. She has had principal responsibility for numerous mergers, acquisitions and dispositions for public and private companies in a wide range of sell-side and buy-side auctions and negotiated transactions.

As leader of the Squire Patton Boggs’ conflict minerals team, Dynda focuses on relevant industries’ best practices in working with clients’ legal, procurement and compliance groups. She advises on developing and reviewing procurement policies,...

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