Tag: form SD

Conflict minerals benchmarking study analyzes filings for 2016—was there any progress?

Development International has posted its most recent Conflict Minerals Benchmarking Study, analyzing the results of filings for the 2016 filing period. The study looked at filings submitted by the 1,153 issuers that had filed conflict minerals disclosures as of July 10, 2017.  The number of issuers filing disclosures for 2016 reflected a decline of 5.6% compared to 2015.  Most interesting, however, is that, notwithstanding statements from Corp Fin, echoed by the Acting SEC Chair at the time, advising companies that they would not face enforcement if they filed only a Form SD and did not include a conflict minerals report, the vast majority of companies continued to file conflict minerals reports.

Consultants report on conflict minerals due diligence and disclosure for 2015. But has it made a difference for the DRC?

by Cydney Posner Two consulting firms, Assent Compliance and Source Intelligence, have published their studies on conflict minerals (tin, tantalum, tungsten and gold) reporting for 2015, the third year of required SEC reporting.  For 2015, there were slightly over 1,200 filers, representing a decrease of about 50 filers from the […]

New study gives mixed reviews to companies filing conflict minerals reports

by Cydney Posner A new study on conflict minerals compliance from Tulane University and Assent Compliance, a compliance software and services firm, revealed that about 90% of filers of conflict minerals reports indicated that they were unable to determine if their products were conflict free, the primary object of the conflict […]

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 […]