1. Complying with Conflict Mineral Rules: Three Steps

    From attorneys at Foley & Lardner, practical advice for complying with the SEC’s conflict minerals reporting rules:

    “Step One: Adopt a ‘responsible sourcing’ policy for conflict minerals and communicate this policy to your suppliers. Make clear your expectation that your suppliers will obtain materials only from ‘conflict-free’ sources, and that you will not tolerate the sourcing of materials from armed groups committing human rights violations. Adopting a ‘responsible sourcing’ policy is the first step in a conflict minerals ‘due diligence’ process, and even if your products do not currently contain ‘conflict minerals,’ having such a policy in place and communicating it to your suppliers will prove beneficial if the mineral composition of your components changes in the future to include conflict minerals, or if the SEC expands the list of ‘conflict minerals’ to include additional minerals besides tin, tantalum, tungsten and gold.”

    Read the rest of the update, Conflict Minerals: Key Initial Compliance Steps for Companies - Foley & Lardner LLP»


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