SEC reporting companies, regardless of their fiscal year, must file a report on new Form SD by Monday, June 2, 2014, if, during calendar year 2013, they used conflict minerals that were necessary to the functionality or production of a product they manufacture or contract to be manufactured. With the reporting deadline fast approaching, such companies should be pushing to finish their relevant inquiries and due diligence, including actively following up with suppliers that have not yet provided necessary information, and accelerating their final preparations for this new conflict minerals disclosure.
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