Conflict Minerals Rule Compliance Toolkit

Resources to help companies understand and comply with the conflict minerals rule, Rule 13p-1 under the Securities Exchange Act of 1934.

Practical Law Corporate & Securities

Section 13(p) of the Securities Exchange Act of 1934 ( (added by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ( ) and Rule 13p-1 under the Exchange Act (the conflict minerals rule) require some reporting companies ( and voluntary filers ( to make specialized disclosure and conduct related due diligence about certain minerals, known as conflict minerals, and their derivative metals contained in the companies' products. Affected companies must make conflict minerals disclosure annually by May 31 (General Instruction B.1, Form SD). Annual Form SD disclosure must cover the company's most recently-completed calendar year. Because the rule requires reporting companies to trace the minerals in their products back through their supply chains, many non-reporting companies that are part of the supply chains of reporting companies are indirectly affected by the rule.

In April 2014, the US Court of Appeals for the District of Columbia Circuit largely upheld the conflict minerals rule against a legal challenge. However, the Court of Appeals concluded that certain of the rule's disclosure requirements violate the First Amendment to the US Constitution. In response to the April 2014 holding, SEC guidance and a formal agency order indicate that the SEC expects companies to comply with the rule's substantive requirements, with certain modifications. This guidance and order remain in effect.

The resources in this toolkit:

  • Help companies analyze how the conflict minerals rule affects them, including in light of the legal challenge to the rule and related SEC guidance.

  • Explain what is required under the rule and identify major interpretive issues.


Practice Notes







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