Conflict Minerals

We have been advising clients for some time regarding the applicability of the rule, as it evolved into its final form and took effect. Some of those engagements include:

  • advising international manufacturing companies on SEC reporting obligations under the conflict minerals rule
  • advising the U.S. operation of a large international manufacturer on the applicability of the conflict minerals rule provisions to various product lines and the diligence process
  • advising a large metals producer on the diligence process and compliance issues with regard to specific products
  • advising a metals importer on the conflict mineral rule’s implications under differing supply chain scenarios
  • advising a gold industry participant on the scope of key terms in the conflict minerals rule
  • advising a large retailer on coverage of the “contract to manufacture” provision of the conflict minerals rule.