October 3, 2014 – October 10, 2014

The summaries provided in this Weekly Recap do not necessarily represent the views of Squire Sanders (US) LLP and should not be deemed to be endorsements of them. The Recap is intended to be a compilation of articles and events to encourage discussion within the conflict minerals community and to keep our readers updated on the most recent developments.

Tulane University’s Study – Year 1 Reports and Cost of Compliance

In an online presentation format, Tulane University’s Payson Center for International Development released a study this past week analyzing the reports filed in the 2014 conflict minerals season. According to a Tulane University press release regarding the study, Tulane University found that reporting companies spent on average approximately $545,00 worth of time and effort to comply with the conflict minerals rule. According to the study, small issuers (those with less than $100 million in revenue) spent on average approximately $190,000 in time and effort to comply with the rule. The press release quotes Dr. Chris Bayer, adjunct lecturer, “This study settles the question of Section 150[2]’s compliance costs to issuers, providing stakeholders with a point of reference and benchmarks.”

In future Recaps, we will present more of the Tulane study’s findings.

Roko Alloys: Conflict Minerals Policy

Roko Alloys, an international recycling company, released its conflict minerals policy. Excerpts from the conflict minerals policy follow. “Roko Alloys has adopted the Electronic Industry Citizenship Coalition (EICC) Code of Conduct. In particular, Roko is fully committed to ensure that the tantalum it sources and mines does not directly or indirectly finance or benefit armed groups that are perpetrators of human rights abuses in the Democratic Republic of the Congo or an adjoining country. Under this policy, Roko Alloys expects all its suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing conflict minerals are DRC conflict free. Roko expects our suppliers to comply with the Electronic Industry Citizenship Coalition (EICC) Code of Conduct and conduct their business in alignment with its policies.”

To read Roko Alloys’ complete conflict minerals policy, please see its conflict minerals policy.