Must Read! District Court Upholds Conflict Mineral Rules

Industry watched closely yesterday as the Washington D.C District Court passed its ruling on the Dodd Frank Conflict Mineral Rules case. The court rejected all of the plaintiffs’ claims and denied the plaintiffs motion for a summary judgment. The Conflict Minerals final rules therefor continue to be in effect as they were passed. This means that all industry sectors that were currently in scope continue to remain so.

The first reporting deadline is fast approaching (May 31, 2014) which means that if an appeal is sought, there is still unlikely to be a change made before this date.

What Does This Mean For You?

If you are an SEC issuer then it’s time to get a program together. This includes:

–          A scope assessment of your product portfolio

–          Creation of a compliance plan

–          Sourcing a software vendor or platform to manage the large amount of data

–          Supplier Engagement

–          Analysis

–          Reporting

If you are not an SEC issuer and do not have to report on May 31st there is a strong possibility that one of your clients will. In this case it is important to have a EICC/GeSI form completed and a corporate policy in place as to help your clients comply and for your firm to remain an upstanding supplier to public SEC issuers.

It is now certain that Conflict Mineral Compliance will be a reality for industry. As with any regulation firms typically move through the Kubler Ross stages of grief. Denial, Anger, Bargaining, Depression Acceptance. As the bargaining phase has now concluded it’s time to move out of depression, into acceptance and get a plan in place. Is your firm Conflict Mineral ready?

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