Debevoise & Plimpton

SEC releases Form SD for conflict minerals disclosure

The SEC recently published Form SD, the disclosure form to be filed by all SEC reporting companies that are subject to the SEC’s conflict minerals rule. Under the conflict minerals rule, which was mandated by the Dodd-Frank Act, a reporting company is subject to the rule and required to file Form SD if it determines that conflict minerals are necessary to the functionality or production of a product that it manufactures or contracts to be manufactured, even if the company determines that the minerals used by it are DRC conflict free.

As a reminder, all SEC reporting companies subject to the conflict minerals rule are required to make initial conflict minerals disclosures on Form SD, for the calendar year commencing 1 January 2013, no later than 2 June 2014 (as 31 May 2014 falls on a Saturday), regardless of their fiscal year-end…

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