SEC Adopts Disclosure Rules on Conflict Minerals

Summary: On August 22, 2012, the United States Securities and Exchange Commission (SEC) adopted Rule 13p-1 and Form SD under the Securities Exchange Act of 1934, as amended, which together with adopting Release No. 34-67716, provide a three-step framework that companies must use to determine whether their products contain “Conflict Minerals” originating in the Democratic Republic of the Congo (DRC) and adjoining countries and related disclosure requirements. Issuers must comply with Rule 13p-1 with respect to the calendar year beginning January 1, 2013, with the first reports on Form SD due on May 31, 2014.