Dodd-Frank Quick Hits – Conflict Minerals – October 2012

Dodd-Frank Quick Hits – Conflict Minerals – Octob...

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. The steps needed to comply with the due diligence requirements are clearer now that the final rule has been issued.

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Some corporations are ahead of the game as they have begun the process of identifying their supply chain for conflict minerals. Now that the rule is final, many corporations are determining how to implement in a calendar year report versus a fiscal year report. KPMG has developed a practical approach for conducting due diligence on conflict minerals.

Compliance with the provision will be a daunting task—many businesses will find it difficult to conduct due diligence on the origin of the conflict minerals. Considering the current ambiguity around the provision, the major hurdle for businesses will be to devise a strategy to determine the source of materials.

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