The comment letters continue to pile up over the Securities and Exchange Commission’s proposal to require disclosure of a company’s use of “conflict minerals” from Central Africa, as companies beg for clarity and flexibility.
The SEC’s proposal, mandated by the Dodd-Frank Act, specifies that companies must determine whether the minerals—several rare compounds commonly used in electronics—appear in their supply chains. If so, the company must also prepare a “Conflict Minerals Report” as part of its annual report and have it audited. According to the proposal, the report should include a description of the company’s “due diligence on the source and chain of custody of the conflict minerals” or its “due diligence in determining that the conflict minerals came from recycled or scrap sources.”
