Note: This blog has been modified from its original version to clarify the distinction between reports that reached a “conflict-free” determination based on RCOI alone versus those that were based on an IPSA. This past spring marked the third year that Form SD Conflict Minerals disclosures … Continue reading
Category Archives: Conflict Minerals
Yamana Gold Discloses Fees for ESG Assurance
Last week, Yamana Gold reported CAD$74,000 of ‘Other Audit Fees’. Normally this would not catch our (or anyone’s) eye, but in this case the other audit fees related “primarily to assurance on the Company’s Conflict-Free Gold Report.” As far as we … Continue reading
Apple Leading the Way on Conflict Minerals
Apple Inc. released its third Conflict Minerals Report yesterday, in which they disclosed reaching a significant milestone. 100% of their 242 identified smelters and refiners are now participating in “independent third party conflict mineral audit programs”. This shows rapid improvement over the … Continue reading
Conflict Minerals: Corp Fin Taking Notes?
Regulations on “Conflict Minerals”, and the section of the Dodd-Frank Act that gave rise to those rules, have seen a fair amount of controversy over the past two years. In a dramatic move, on August 18, 2015 the US Court of Appeals reaffirmed its … Continue reading
Analyzing Conflict Mineral Reporting in Year 2
The 2015 filing season marks the second year of conflict mineral reporting for public companies. In all, there have been 1,279 reports – Form SD (Specialized Disclosure) – filed since January 1, 2015. This is down from the 1,330 reports filed … Continue reading
An Initial Look at Conflict Minerals; Dodd Frank Section 1502
On April 14, 2014, the United States Court of Appeals for the District of Columbia Circuit issued a decision in National Association of Manufacturers, et al. v. SEC, et al., No. 13-5252 (D.C. Cir. April 14, 2014). The Court concluded … Continue reading