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Client Alert 30 October 2013 Conflict Mineral Disclosure Requirements Applicable Law: Section 1502 of the Doddering Wall Street Reform and Consumer Protection Act (Doddering) requires companies to

How to fill out conflict mineral disclosure

How to Fill Out Conflict Mineral Disclosure:

1. Review the SEC's disclosure requirements: Familiarize yourself with the guidelines and regulations outlined by the Securities and Exchange Commission (SEC) regarding conflict mineral disclosure. This will provide you with an understanding of the necessary steps and information required for the disclosure.
2. Identify applicable conflict minerals: Determine if your company uses or sources any of the four conflict minerals defined by the SEC, which include tantalum, tin, tungsten, and gold. Assess your supply chain to identify potential sources of these minerals in your products.
3. Conduct a reasonable country of origin inquiry (RCOI): In order to disclose the presence of conflict minerals, you must conduct an RCOI. This inquiry involves investigating the origin of the minerals used in your products and determining if they are sourced from conflict-affected regions, such as the Democratic Republic of Congo or its neighboring countries.
4. Establish due diligence measures: Develop and implement due diligence measures to ensure responsible sourcing practices. This may involve engaging with suppliers, conducting audits, or adopting industry-recognized frameworks such as the Responsible Minerals Initiative (RMI) or the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance.
5. Collect and analyze required data: Gather relevant information from your supply chain, such as smelter or refiner data, and assess the source and chain of custody of the conflict minerals. Analyze the data to determine if they originated from conflict-affected regions.
6. Prepare the necessary forms: Fill out the appropriate disclosure forms, such as Form SD and the Conflict Minerals Report, as required by the SEC. Provide detailed information about your conflict mineral due diligence process, the presence of conflict minerals in your products, and steps taken to mitigate the risks associated with these minerals.

Who Needs Conflict Mineral Disclosure:

1. Publicly traded companies: The SEC's conflict mineral disclosure requirements primarily apply to companies that are registered with the SEC and file reports under the Securities Exchange Act of 1934. This includes both domestic and foreign companies whose products could potentially contain conflict minerals.
2. Companies using or sourcing conflict minerals: Any company that uses or sources tantalum, tin, tungsten, or gold in its products must comply with conflict mineral disclosure requirements if they meet the criteria set by the SEC. This includes companies across various industries, such as electronics, automotive, jewelry, aerospace, and more.
3. Companies with complex supply chains: Businesses with complex supply chains and multiple tiers of suppliers often face challenges in tracing the origin of conflict minerals. These companies must implement robust due diligence measures and disclose their efforts to mitigate the risks associated with conflict minerals.

Note: It is essential to consult legal and compliance experts or refer to the SEC's official guidelines to ensure accurate and up-to-date information regarding conflict mineral disclosure.

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What is conflict mineral disclosure?

Conflict mineral disclosure is a requirement for companies to report on the use of certain minerals sourced from conflict-affected or high-risk areas.

Who is required to file conflict mineral disclosure?

Companies that are publicly traded in the United States and use conflict minerals in their products are required to file conflict mineral disclosure.

How to fill out conflict mineral disclosure?

Companies must conduct due diligence to determine the source of their conflict minerals and report their findings on a specialized form called Form SD.

What is the purpose of conflict mineral disclosure?

The purpose of conflict mineral disclosure is to promote transparency and responsible sourcing practices in the supply chain of electronic and automotive industries.

What information must be reported on conflict mineral disclosure?

Companies must disclose the source of their conflict minerals, the country of origin, and the efforts made to trace their supply chain.