Companies that are publicly traded in the USA (called „issuers“ under the law) need to disclose whether or not conflict minerals that are necessary to the functionality or production of a product they manufacture originated in the Democratic Republic of the Congo. If they did, they must submit a report to the Securities and Exchange Commission (including due diligence specification and an independent third party audit).
Companies not publicly traded in the USA are not directly affected by the Dodd-Frank Act, which means they are not legally required to proactively deal with conflict minerals reporting. However, any company which is a supplier of publicly traded US companies will be indirectly affected, because the reporting requirements are passed down the supply chain. This means that requests from customer companies need to be dealt with.
On May 19, 2017, EU Conflict Minerals Regulation was published in the Official Journal of the European Union. The new Regulation will take effect on January 1, 2021. This FAQ document outlines key elements of the new law.
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