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Heads Up: Conflict Minerals — The Supply Chain’s Weakest Link?

Volume 18, Issue 38


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This Heads Up discusses potential implementation issues identified in comment letters on the SEC’s December 2010 proposed rule on conflict minerals and in the Commission’s October 18, 2011, roundtables. Under the proposed rule, registrants that assert that conflict minerals are used in, or are necessary to the functionality of, any of their products would be required to disclose whether those conflict minerals originated in the Democratic Republic of Congo or an adjoining country. Key topics addressed at the roundtable included the proposal’s scope, determination of the reasonable country of origin, due-diligence considerations, and reporting and auditing requirements.

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