Navigating the SEC's New Conflict Minerals Disclosure Requirements
April 11, 2013, Webinar from 1:00PM - 2:00PM EST
The SEC recently approved the much debated conflict minerals due-diligence disclosure rules that were originally developed in the Dodd-Frank Wall Street Reform and Consumer Protection Act. The rule requires public companies to disclose the use of any conflict minerals that “are necessary to the functionality or production of a product manufactured” or “contracted to be manufactured” by that company. While not banning the use of conflict minerals, it does require companies to assess their supply chains and publically disclose their use of the minerals.
The rule impacts thousands of companies, both U.S. and foreign, that file reports with the SEC. However, it also impacts privately owned companies who are suppliers to public companies. Companies manufacturing products that intentionally include any amount of tin, tantalum, tungsten or gold (or their ores) must comply. The SEC’s final rule could impact manufacturers in the medical device industry in a number of ways. Given the wide variety of medical devices, it is unavoidable that conflict minerals will be used as part of US FDA approved medical devices. For example, tin and gold are used for soldering metals; tungsten and tantalum are used for their radiopaque characteristics in implantable medical devices. Tantalum capacitors are used in many electronic medical devices. Typically, medical device companies sub-source parts with potential conflict minerals which are then incorporated within the finished medical device. On a broader scale, if your company is producing either components or finished medical devices for customers, then you will need to understand the nuances of your supply-chain position in relation to the SEC's rule.
Ron Klein, a member of Holland & Knight's Public Policy & Regulation Group, has worked in the private sector as a business and transactional attorney for over 20 years, as well as the public sector as an elected official in both Tallahassee and Washington, D.C. This experience offers a distinctive combination of skill sets in having worked and advised private sector principals and management on business and legal issues, as well as having served in the Florida House, Senate and U.S. House of Representatives. Mr. Klein's experience gives clients an added edge in having their advocate understand their issues and concerns, as well as the knowledge, resources, and relationships to help them make the best strategic business decisions.
Ronald A. Oleynik is a partner practicing in Holland & Knight's Washington, D.C., office in the area of international trade regulation. His experience includes a broad range of industrial security, customs, export and international trade matters. In the area of customs, his experience includes custom classification and valuation, rules of origin, and special duty programs such as GSP, NAFTA, CBI, and CBPTA; as well as trade policy representation before the Executive Branch and Congress regarding the WTO, CBI, CBPTA, FTAA, and other trade multi- and bi-lateral trade negotiations.
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