Conflict Minerals Rule Compliance

Summary

This practice note discusses the rules adopted by the U.S. Securities and Exchange Commission (SEC) under the Securities Exchange Act of 1934, as amended (Exchange Act), to implement Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (111 P.L. 203), known as the "Conflict Minerals Rule." As a result of Conflict Minerals Rule, certain issuers who have reporting obligations under Section 13(a) (15 U.S.C. § 78m) or 15(d) (15 U.S.C. § 78o) of the Exchange Act must assess whether any products that they manufacture or contract to manufacture contain "conflict minerals," as defined under the Conflict Minerals Rule, that are necessary to the functionality or production of their products.