Dodd-Frank Quick Hits — Conflict Minerals — June 2012


This publication highlights KPMG’s involvement with the World Gold Council, KPMG as a hot topic with investors, the OECD joint forum on implementation, and an update on activity around this topic.

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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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