More than one month before the deadline, the question of who will be the first company to file their SEC conflict minerals disclosure has been answered. Siliconware Precision Industries Co., Ltd. out of Taiwan wins the trophy for first across the line.
There is now likely to be a collective sigh of relief from other SEC issuers that someone ELSE went first. The notable aspects of the filing are its brevity and its classification of both undeterminable and DRC Conflict Free. The filer did not make clear if the DRC Conflict Free status is due to scrap/recycle sourcing or conflict free DRC-origin materials – the SD does not include the scrap/recycle source language, yet no IPSA was conducted. Question number 15 of SEC’s new Q&A clarifies that even where an issuer claims some products are undeterminable, products qualifying as non-scrap DRC Conflict Free cannot be described as such without an IPSA.
Some experts have expressed surprise that the filing was made at this time given the uncertainty of the submittal deadline based on the recent Appellate court decision.
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