March 28, 2014 - April 4, 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.

Canadian House of Commons Begins Debating Conflict Minerals Act

Paul Dewar, a Member of Parliament and sponsor of the Conflict Minerals Act, wrote an op-ed in the Toronto Star urging all parties to support the Act, as the House of Commons began debating the Conflict Minerals Act this past week.

In his op-ed, Mr. Dewar summarized his proposed bill stating, ”This bill requires Canadian companies using minerals from the [Great Lakes Region of Africa] to exercise due diligence to ensure that no armed groups engaged in illegal activities have benefited from the extraction, processing, or use of those minerals. Companies would have to publish their findings on their website and in documents filed with the Canadian government. The government would then share the report with the producing countries.”

We will continue to keep you apprised of any recent developments in regards to the Canadian Conflict Minerals Act.

Michael Kors – Conflict Minerals Policy

Michael Kors, a global luxury fashion brand, released its conflict minerals policy. Excerpts from the policy follow.

“Michael Kors does not directly source conflict minerals from mines, smelters or refiners, and is many levels removed from these market participants. We therefore require the cooperation of our suppliers in the implementation of this policy and in enabling Michael Kors to meet its SEC compliance obligations. Suppliers are expected to:

  • Put in place procedures for the traceability of conflict minerals;
  • Cooperate with our conflict minerals due diligence process, which includes providing us, from time to time, with written certifications and other information concerning the origin of conflict minerals included in products and/or components supplied to Michael Kors;
  • Maintain reviewable business records supporting the source of conflict minerals;
  • Adopt policies and procedures with respect to conflict minerals consistent with Michael Kors’ policy and practices set forth herein and the OECD Guidance, including the adoption of a risk mitigation strategy to respond to identified risks in the supply chain, and communicate such policies and procedures to their personnel, direct suppliers and indirect suppliers; and
  • Require their direct and indirect suppliers to adopt policies and procedures that are consistent with our Conflict Minerals Policy.”