The Conflict Minerals Rule was adopted during August 2012 and took effect at the beginning of 2013. Since then, many companies have made significant progress in addressing the requirements of this complex rule, moving from determining applicability through establishing a compliance team, developing compliance procedures, and engaging in product filtering and vendor outreach. Some companies are even fairly far along in validating vendor responses and have prepared initial drafts of their Form SD and accompanying conflict minerals report.
However, to paraphrase Winston Churchill, most companies are not at the end or even at the beginning of the end of the compliance process. Rather, they are approaching the end of the beginning. With that in mind, this white paper from Schulte Roth & Zabel— leaders in Conflict Minerals Rule and responsible sourcing compliance—offers observations and recommended action items for the first filing, the remainder of 2014, and beyond.
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