This publication focuses on the industry-wide implications of the conflict minerals provision of the Dodd-Frank Act, by highlighting the final rules, the implication of those rules, outlining how companies should comply, and details on mapping and disclosures.
The conflict minerals rule, which falls under section 1502 of the Dodd-Frank Act, affects any industry that has 3TG in its supply chain. 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.