Conflict mineral rules: frequently asked questions - .PDF file.
The US Securities and Exchange Commission’s (SEC) conflict mineral rules, adopted in August 2012, present hard questions for public companies, which must evaluate whether they are covered by the rules, and, if so, make inquiry into the origin of the minerals used in their products. The rules are complex and leave much to interpretation based on particular facts and circumstances. Further, the rules endorse an international due diligence framework that is somewhat untested and will continue to evolve as the impact of the rules takes effect.
Click on the link above to download this Covington & Burling briefing.