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A review of the first wave of conflict mineral filings
This Davis Polk survey notes that SEC reporting companies were required to provide disclosure about conflict minerals by May 31, 2014 for the prior calendar year on Form SD (for “specialized disclosure”).
To see how companies have begun to interpret their obligations under the new rule, Davis Polk inspected a sample of companies from the first wave of Form SD filings by S&P 500, S&P Midcap 400, and non-US SEC reporting companies in the S&P Global 1200.
Posted with permission from Davis Polk, copyright 2014.