Conflict Minerals Disclosure Guidelines

On August 22, 2012, the Securities and Exchange Commission ("SEC") adopted final rules to implement the reporting requirements relating to "conflict minerals" under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. On the same date the SEC also adopted rules requiring resource extraction issuers to disclose information relating to their commercial development of oil, natural gas or minerals.  For more information about these rules, see our client advisory dated September 28, relating to Resource Extraction Issuers.

The new reporting requirements relating to "conflict minerals" apply to all issuers that file annual reports with the SEC under the Exchange Act, including small businesses and foreign private issuers. Under the new disclosure requirements, issuers must file an annual conflict minerals report on new Form SD. The Form SD will be filed by all such issuers, regardless of their fiscal year-end, for the first time on May 31, 2014