Perspectives

Year 1 Form SD and Conflict Minerals report

Navigating next steps

With legal action against the SEC regarding the constitutionality of certain disclosures under its final rule on conflict minerals still partially unresolved, more than 1,300 registrants submitted their first conflict minerals filing by mid-2014. This Heads Up discusses findings from our analysis of registrants´ first filing under the SEC´s final rule on conflict minerals and provides insights for registrants as they consider conflict minerals compliance and reporting improvements for future filings in anticipation of an independent private sector audit (IPSA). How did you navigate year one...and are you ready for year 2?

In light of the legal developments leading up to the first filing deadline, we have undertaken to provide observations and insights for registrants to consider related to Year 1 reporting trends as well as recommendations for registrants as they seek to enhance their conflict minerals due diligence processes and reporting practices for Year 2. Our observations are informed by our experience working with clients on compliance with their reporting requirements and take into account the future IPSA requirement.

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