On September 12, 2012, the Federal Register published the SEC’s Conflict Minerals Rules, which were adopted on August 22, 2012. These final rules require all reporting issuers to disclose supply chain and sourcing information regarding several minerals and metals, termed “conflict minerals,” contained in products that the issuers manufacture or contract to manufacture in each calendar year, beginning on January 1, 2013. The initial disclosure is due no later than May 31, 2014. The rules are expected to apply to approximately 6,000 of 14,600 total issuers. The SEC also adopted final rules that require resource extraction issuers to disclose information relating to any payment made to a foreign government or the US Federal Government on or after October 1, 2013 for the purpose of the commercial development of oil, natural gas or minerals. This disclosure must be filed within 150 days of an issuer’s fiscal year-end, beginning with fiscal years ending after September 30, 2013.
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