Tag Archives: Georgetown Law School

Our Conquest of the Mt. Everest of Conflict Minerals is Complete

Elm and The Georgetown Law School have finished the reviews of all 1300 SEC conflict minerals filings, data collection and final consistency reviews.

As we described previously, this effort involved reading every Form SD and Conflict Minerals Report filed with the SEC and assessing each against twenty substantive criteria.  In addition, we collected SIC code information from the filers as well as from the broader universe of all SEC issuers.  We believe this is the deepest, most comprehensive analysis yet conducted of the conflict minerals filings.

Comparing our final findings with the interim information we released in August, some things changed and some stayed the same.

One fascinating data point:

Our final tally of the potential filers (foreign and domestic filers active in 2013 across all 268 SIC codes represented in the submissions) came to 5,982 –  99.8% of the number of issuers the SEC originally estimated would file.

Additional insights will be included in our upcoming presentations  at various venues soon, and a white paper is also forthcoming, and The Wall Street Journal recently wrote up some interesting data on suppliers from the study.  The most detailed analysis, however, is provided to clients requesting company-specific benchmarking (already underway).  Contact us if you are interested in your own benchmarking review.

With this effort complete, we acknowledge the significant efforts of – and are deeply grateful to – the entire team who spent countless (painful) hours on this.  Thanks go out to the Georgetown group of Collmann Griffin, Beth Palkovic, Weiwei He, Delia Solomon, Nick Brock, and Jacqueline Johnston, and to our own Stacy Hibiske.  We also want to acknowledge Brad Brooks-Rubin for connecting Georgetown to us.

Sneak Peek – 850 Conflict Minerals Disclosures Reviewed by Elm and Georgetown Law School

We previously announced that we are conducting a thorough review of all the 2013 conflict minerals filings and that Georgetown Law School has joined the effort.  So far, the team has reviewed approximately 850 of the 1300, and here are a few interesting things we have found.

Number of unique SIC codes across all 1300 filers:  268




Percent of the 850 filing only a Form SD:  17%

Number of relevant suppliers:

High – 38,700

Low – 1

Average – 835





These are only a few of the 20 criteria assessed.  When the effort is complete, Georgetown will use the data as the basis for additional legal analysis.  Elm will make it available on a customized basis for client engagements, presentations and further publications.

Georgetown Law School Joins Elm Conflict Minerals Study

We are pleased to announce that Georgetown Law School (GLS) is participating in our analysis of the 2013 conflict minerals SEC filings.  It is our belief that this will be the most comprehensive review of the 2013 Form SDs and Conflict Minerals Reports (CMRs) conducted.

Elm has read almost half of the 1300+ filings and collected data on twenty criteria.  GLS is reviewing the remaining filings and collecting the same data.

Once completed, the data will be used by GLS for their own independent, impartial and academic studies.  Elm will use the same data for our business purposes which include conducting company-level benchmarking reports.  The data will also form the basis for future Elm presentations and publications.