Dodd-Frank Quick Hits Alert — Conflict Minerals — February 2012

Dodd-Frank Quick Hits Alert — Conflict Minerals —...

This publication discusses the findings that several companies have adopted CM policies ahead of the finalized rule.

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The conflict minerals provision, contained in Section 1502 of the Dodd-Frank Act, has a direct bearing on reporting requirements on about one-half of all publicly traded companies in the United States.

Complying with the due diligence requirements of the provision is daunting and unclear; many corporations are waiting for the SEC to issue the final rule before the end of the year. However, several corporations and industry groups have begun to trace conflict materials in their supply chain, rather than wait for the SEC’s final rules, due to the tight time line for implementation once the ruling is finalized.

KPMG has developed a practical approach for conducting due diligence on conflict minerals.

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