Conflict Minerals: What Issuers Should Know

This article is a summary of certain provisions of the Dodd-Frank Act and the proposed rules of the Securities and Exchange Commission (SEC) relating to conflict minerals. This summary has been prepared in order to assist companies to better understand the scope of the rules the SEC is required to implement. We emphasize that the SEC has not as yet adopted its final rules, and therefore the guidance set forth herein is subject to the qualification that the SEC’s final rules may differ from its proposed rules. We encourage you to discuss the matters reviewed in this summary with Hogan Lovells lawyers, both to review the statutory and proposed rulemaking provisions in greater detail and to consider the implications of these provisions to the specific business operations in which you are engaged.


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