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Conflict Minerals: What to Expect When You’re Expecting to Report

Section 1502 of the Dodd-Frank Act took effect January 1, 2013, and companies will submit their first conflict minerals reports—which will be publicly available—to the U.S. Securities and Exchange Commission (SEC) on May 31, 2014.

While the final SEC rule provided more clarity on the requirements that companies will need to fulfill as they report on the use of tin, tungsten, tantalum, and gold in their supply chains, the rule is far from clear. For example, expectations for how companies should conduct “due diligence” and reasonable country-of-origin inquiries are ambiguous.

The SEC has acknowledged that NGOs and investors will play an integral role in monitoring and analyzing what companies disclose in their reports. It is in these stakeholders’ best interest, as well as that of companies, to make reporting efforts practical, consistent, and straightforward.

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