By Michael Littenberg, Farzad Damania and Joseph Valane, Schulte Roth & Zabel LLP
This Note offers guidance on the due diligence required by the Securities and Exchange Commission’s (SEC) proposed rules implementing Section 1502 of the Dodd-Frank Act, the conflict minerals provision. It lists and discusses resources that may assist companies with conflict minerals due diligence. The Note also describes significant uncertainties about the final rules.
This Note discusses:
- Which companies will be affected by Section 1502.
- The effective date of Section 1502’s diligence and disclosure requirements (assuming final rules are adopted as proposed by the end of 2011).
- The three main steps of conflict minerals due diligence that reporting companies may need to conduct depending on whether they use conflict minerals and, if so, the minerals’ country of origin.
- Resources that may assist companies conducting conflict minerals due diligence.
- Major uncertainties about the final rules.
(Read the full note (PDF))