As a reminder, conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2018. As you may recall, in April 2017, the SEC’s Division of Corporation Finance issued blanket no-action relief, saying it would not recommend enforcement against companies for not complying with the requirement to file a “conflict minerals report,” although it would expect companies with conflict minerals in their supply chains to file a Form SD. (See our previous client alert, available here). Many companies did not avail themselves of that relief, however, given that they already had done the legwork to prepare their conflict minerals reports and stakeholders had come to expect them.
Without any notable regulatory updates since April 2017, many companies have stayed the course and likely will file similar disclosures this year.