Key Takeaways From SEC Roundtable on Conflict Minerals


This publication identifies a rule under the Dodd-Frank Act Section 1502 Conflict Minerals reporting requirements that requires companies to report if their products contain 3TG minerals and if they were mined in a location with inhumane practices.

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The conflict mineral rule, which falls under section 1502 of the Dodd-Frank Act, is a highly discussed topic affecting any industry that has 3TG in its supply chain of products. Panelists from the industry, trade associations and NGOs seemed to be in support of Section 1502, and there was healthy debate on several key terms and definitions.

The industry asked for clarification on several provisions of the proposed rules (e.g., necessary to manufacturing, de minimis rule) and relief on several others (e.g., recycling). The overwhelming sentiment was to leave flexibility in the regulations and that the SEC should provide clarifications via examples where required.

In addition, panelists agreed that the focus should be on the due diligence process rather than content or outcome. Everyone seemed supportive of the SEC's proposed rules.

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