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ARTICLE · 10 FEBRUARY 2015

Conflict Minerals Rules

A&O Shearman
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Under the Conflict Minerals Rule, SEC reporting companies that manufacture products that contain tantalum, tin, tungsten or gold face specific reporting requirements.

United StatesCorporate/Commercial Law

On 18 November 2014, the United States Court of Appeals for the District of Columbia Circuit granted a petition filed by the US Securities and Exchange Commission ("SEC") and Amnesty International for rehearing of a case that invalidated a portion of the SEC reporting requirements regarding conflict minerals originating in the Democratic Republic of the Congo and adjoining countries (the "Conflict Minerals Rule"). The court's decision, once the case is reheard, could potentially affect the existing scope and application of the Conflict Minerals Rule. The Conflict Minerals Rule is set forth in Form SD – Specialized Disclosure Report, which is required under Rule 13p-1 under the Securities Exchange Act of 1934 (the "Exchange Act").

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