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Latest conflict minerals filings show improved due diligence

Joe Mont | June 21, 2016

Despite legal uncertainty and logistical difficulties, the show must go on for conflict minerals disclosures demanded by the Securities and Exchange Commission. In fact, experts say, many companies, voluntarily, took the reporting much more seriously this year.

The disclosures—pertaining to supply chain evidence of tin, tantalum, tungsten, and gold mined in the war-torn Congo—were due on May 31. By an initial breakdown, more than 1,201 Form SDs were submitted, along with more than 970 Conflict Mineral Reports, a deeper dive into supply chain investigations filed online and as an exhibit to Form SD.

CMRs as envisioned by the SEC, were a demand for companies determining that they were not conflict-free to detail due diligence efforts on the source and chain of custody of their conflict minerals and illustrate adherence to a “a nationally or internationally recognized due diligence framework,” such as the one approved by the Organisation for Economic Co-operation and...

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