Conflict Minerals Compliance Basics: Relevant Dates and Deadlines

In our final installment of "Conflict Minerals Compliance Basics," and with today being an important conflict minerals date, we will be covering relevant dates and deadlines.

The SEC deadline for filing Form SD is 31 May 2014. If companies determine that they do need to file a Conflict Mineral Report, the law says that companies will need to file their report on information gathered in the first full fiscal year after the rule is issued. So if a company’s fiscal year is Jan 1st – Dec 31st, the first report they will have to submit will be about fiscal year 2013 and they will submit it in early 2014. Some companies are encouraging the SEC to declare one calendar date when all companies will have to submit. This would make it easier for suppliers who have multiple customers filing to collect and distribute their information just once every year, rather than meet the timing of many different fiscal periods. In a consolidated industry such as the IT sector, it would be easiest for the entire industry to be asking for the information simultaneously. This might even motivate the unresponsive sub-sub-contractors to provide information.

If you have any further question regarding conflict mineral compliance, please email Source Intelligence.

If you wish to read any of our previous “Conflict Minerals Compliance Basics” please go to Source Intelligence’s 3BL page.