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The D&O Diary

A Periodic Journal Containing Items of Interest From the World of Directors & Officers Liability, With Occasional Commentary

Conflicts Minerals

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D.C. Circuit Strikes Down SEC Conflicts Minerals Rules in Part, Upholds Other Provisions

By Kevin LaCroix on April 15, 2014
Posted in Conflicts Minerals

dccircuitIn an April 14, 2014 Opinion (here), the D.C. Circuit struck down a portion of the SEC’s conflicts minerals rules as violative of the First Amendment, while at the same time upholding the other challenged portions of the Rules. A majority of the appellate panel found that the rules’ requirement that companies must …

The Complex Conflicts Minerals Disclosure Challenge

By Kevin LaCroix on April 22, 2013
Posted in Conflicts Minerals, Corporate Governance

The SEC’s conflicts minerals disclosure rules, promulgated as required under provisions of the Dodd-Frank Act, became effective on January 1, 2013, requiring companies to make their first conflict minerals disclosures on or before May 31, 2014 for the 2013 reporting year, as I detailed in a recent post. But though it is widely recognized…

Time to Look at the Conflict Minerals Disclosure Requirements

By Kevin LaCroix on March 7, 2013
Posted in Conflicts Minerals, Corporate Governance

Although I was aware that among the Dodd-Frank Act’s hundreds of pages are provisions relating to so-called “conflict minerals,” until recently I had not had to pay much attention to these provisions. But now, for whatever reason, the conflict minerals disclosure requirements suddenly have hit the center of my radar screen. I have had…

Kevin M. LaCroix is an attorney and Executive Vice President, RT ProExec, a division of RT Specialty. RT ProExec is an insurance intermediary focused exclusively on management liability issues…

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