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.