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Heads Up — Conflict minerals — The supply chain’s weakest link?

Published on: Nov 29, 2011

This issue of Heads Up discusses potential implementation issues identified in comment letters on the Commission’s December 2010 proposed rule on conflict minerals and in the SEC’s 18 October 2011 roundtables. Under the proposed rule, registrants that assert that conflict minerals are used in, or are necessary to the functionality of, any of their products would be required to disclose whether those conflict minerals originated in the Democratic Republic of Congo or an adjoining country. Key topics addressed at the roundtable included the proposal’s scope, determination of the reasonable country of origin, due-diligence considerations, and reporting and auditing requirements.

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