See this important follow up to Higgins’ comments.
The BloombergBNA Daily Environment Report for September 17, 2014 contains a write up of comments made by SEC Division of Corporation Finance Director Keith Higgins about the first year conflict minerals disclosures. Higgins spoke at the American Bar Association’s Business Law Section meeting in Chicago. The article discusses three points offered by Higgins:
- Clarifying RCOI activities.
- Concern over inferences that may be drawn from an issuers’ disclosure language.
- Disclosure of processing facilities, even for “undeterminable” products. We won’t give it away, but the BNA article provides something we found very interesting about this point.
Interestingly, in our study with Georgetown Law School of all SEC conflict minerals filings, we have data concerning the overlap between the RCOI and Due Diligence measures, as well as listing smelters/refiners.