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Press Release: On April 29, 2014, the Securities and Exchange Commission (SEC) issued guidance in response to a Court of Appeals decision concerning the conflict minerals provisions of the Dodd-Frank Act, and the SEC rules implementing those provisions. The court upheld Dodd-Frank, but declared one provision forcing particular language to be a violation of the First Amendment. The Court rejected the many other challenges to the SEC rules made by the appellants in the case. In its guidance, the SEC stated that it expects covered companies to file forms and reports required by its conflict minerals rules on or before June 2, 2014, as previously mandated by the SEC rules. Companies that are covered by Dodd-Frank are those that are listed with the SEC and file reports with that agency. The guidance also made clear that the conflict minerals filings should comply with all aspects of the SEC rules, other than the specific obligation found to violate the First Amendment. Thus, covered companies must still inquire about the country of origin of conflict minerals – tin, tungsten, tantalum and gold. They must also report on their supply-chain due diligence regarding any conflict minerals that originated, or may have originated, in the Democratic Republic of the Congo or an adjoining country. Cecilia Gardner, JVC’s CEO, president and general counsel, stated, “The SEC’s guidance makes clear that companies in our industry covered by Dodd-Frank must be ready to submit filings by June 2, 2014. This will require cooperation from every business in their gold and tungsten supply chains. Suppliers should take steps now to implement supply chain assurance systems.” JVC’s recently published Supply Chain Assurance Kit, a do-it-yourself kit to help suppliers of gold and tungsten implement assurance systems, is available on its website at www.jvclegal.org. Please call JVC at 212.997.2002 if you have questions. View the SEC’s guidance.
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