Date: Jul 24, 2014
Keller and Heckman Partner Eric Gotting discussed the implementation of the Securities and Exchange Commission’s (SEC) Conflict Minerals Rule on July 10 at the IPC Conflict Mineral Conference. A significant development, he told attendees, was when SEC recently provided oral confirmation that metal compounds are not subject to the rule. SEC agreed that that metal compounds are chemically distinct from metals, he explained.
As a result, Mr. Gotting said, manufacturers who use a metal compound in the manufacturing process do not need to comply with the rule’s reporting and supply chain analysis requirements. However, he cautioned that manufacturers who make the compound do need to comply with the rule.
For more information about SEC’s Conflict Minerals Rule, contact Eric P. Gotting at firstname.lastname@example.org or 202 434-4269.