So much work has been put into vetting suppliers and assessing products for compliance with new conflict minerals disclosure requirements that many companies may have not yet fully considered the actual filing protocol that is the end game for those supply chain reviews.

When companies do crack into the Securities and Exchange Commission’s new Form SDโ€”a new form created for conflicts minerals reporting and other โ€œspecial disclosuresโ€โ€”it may feel unfamiliar. Rather than straightforward quantitative and check-the-box reporting, the atypical form asks for narratives and open-ended discussion of the issue.