Reminder: Conflict Minerals Disclosure Due By May 31, 2014

The deadline is approaching for companies to comply with the SEC's disclosure rules relating to the presence of conflict minerals in manufactured products. Conflict minerals are minerals whose production contributes to the financing of armed conflict and human rights abuses in and around the Democratic Republic of the Congo (DRC). The disclosure rules apply to SEC-reporting companies, including MJDS companies and other foreign private issuers, if conflict minerals are necessary to the functionality or production of a product that the company manufactures or contracts to have manufactured.¹

The required conflict minerals disclosure must appear in a specialized disclosure report filed with the SEC on Form SD, which is due annually by May 31 for the prior calendar year. This bulletin summarizes the steps that SEC-reporting companies should be taking to prepare their first Form SD. The SEC's flow chart showing these steps is reproduced in Appendix A.