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.