Tag: conflict minerals

This year’s conflict minerals filings show some improvement, according to early review

by Cydney Posner An early review of conflict minerals filings for the 2014 reporting period shows improvement in “detail, clarity and quality,” according to this article in BNA. As reported by Elm Sustainability Partners, a conflict minerals consulting firm, there were 1,272 filers for the 2014 reporting period, compared to 1,328 for […]

Amnesty International and Global Witness scold companies for poor performance in complying with conflict minerals rule

by Cydney Posner Amnesty International and Global Witness have posted a paper, “Digging for Transparency,” evaluating the performance by 100 public companies in their inaugural season of conflict minerals reporting. The overall reaction: major disappointment.

What have the conflict minerals rules cost the SEC?

by Cydney Posner Sure, companies have spent millions and millions on conflict minerals compliance. But what have the conflict minerals rules cost the SEC? According to Reuters, reporting on a response by SEC Chair Mary Jo White to a request by a group of Republican House members, the SEC “has […]

CFSI posts “Five Practical Steps to Support SEC Conflict Minerals Disclosure”

by Cydney Posner The Conflict-Free Sourcing Initiative has posted an updated 2015 version of its practical guidance white paper on conflict minerals specifically for downstream companies, called “Five Practical Steps to Support SEC Conflict Minerals Disclosure.” CFSI’s Practical Steps is designed  to provide more flexible guidance to downstream companies in satisfying […]

Will Congress revisit the conflict minerals rule?

by Cydney Posner According to a Bloomberg BNA report, a representative of the Chamber of Commerce, one of the plaintiffs in National Association of Manufacturers, Inc. v. SEC, the conflict minerals case currently pending in the DC Circuit, claims that the litigation “is sparking new interest by Congress in the requirements.” Don’t […]

House Republicans pressure SEC to end court battle over conflict minerals rule

by Cydney Posner According to this article from The Washington Post with Bloomberg, in February, House Financial Services Committee Chair Jeb Hensarling and three other House members (Scott Garrett of New Jersey, Bill Huizenga of Michigan, and Ed Royce of California) sent a letter to SEC Chair Mary Jo White urging […]

AICPA suggests management representations for auditors to seek in connection with conflict minerals reporting

by Cydney Posner The AICPA has issued an FAQ that identifies, for auditors conducting Independent Private Sector Audits for inclusion in Conflict Mineral Reports, the types of management representations that auditors should consider seeking from managements of companies. Not surprisingly, the AICPA does not disappoint — the suggested reps are, shall […]

Conflict minerals report can now be filed on EDGAR as Exhibit 1.01 to Form SD

by Cydney Posner Form SD provides that companies are to file the conflict minerals report as Exhibit 1.01, as does the SEC final release.  Last year, however, Exhibit 1.01 was not technically available for EDGAR filings, and the SEC’s EDGAR office advised that the CMR should instead be filed as […]

Appellants file supplemental brief opposing conflict minerals disclosure requirement

by Cydney Posner In the final week of 2014, appellants National Association of Manufacturers, U.S. Chamber of Commerce and Business Roundtable filed their supplemental brief in the conflict minerals case, National Association of Manufacturers, Inc. v. SEC. The brief was filed in response to the order of the D.C. Circuit Court of […]

SEC, Amnesty and others file briefs in support of upholding the conflict minerals disclosure requirement

by Cydney Posner In November, the D.C. Circuit Court of Appeals granted the petitions of the SEC and Amnesty International for panel rehearing in connection with the conflict minerals case, National Association of Manufacturers, Inc. v. SEC. The order of the Circuit Court directed the parties to file supplemental briefs […]