This past August, the SEC released its final rule under Section 1502 of the Dodd-Frank Act establishing new due diligence and disclosure requirements for companies that manufacture products containing conflict minerals. The new rule aims to increase public pressure on public and certain private manufacturing companies, as well as their suppliers (whether public or privately held), to cease purchasing or using certain minerals, or materials containing certain minerals, from the Democratic Republic of the Congo and a number of adjoining countries. Congress believes the sale of these minerals is helping to finance conflict and accompanying human rights abuses in this region of the world.
As we approach the rule's effective date, we invite you to join Goodwin Procter partner Michael Giannotto for a one-hour webinar to examine the practical implications of this new rule. Specifically we will discuss:
- Timing: Implementation and reporting; how to determine if your company must file a report under the rule.
- Best practices for manufacturers: Inquiries that should be made, data that should be collected, and arrangements with suppliers and other upstream companies that should be implemented by public manufacturing companies and other companies subject to the rule.
- Best practices for entities in a manufacturer's supply chain: The rule will affect not only publicly-traded manufacturing companies, but also certain private issuers and various other entities in a public company's supply chain, such as mining companies, refineries, component suppliers, and outsourced manufacturing companies. We will discuss best practices for companies indirectly affected by the rule.
- Potential legal and practical consequences: Penalties for failure to comply or to comply fully, including possible SEC enforcement and private rights of action.
This webinar will be useful not only for public issuers, but for any company that is a supplier to a public issuer subject to this rule. Please join us.
See the Webinar Slides.