Conflict Minerals: Intel Files Conflict Minerals Report

May 22, 2014 | Steve Quinlivan, Stinson Leonard Street
View Original

The holy grail (at least so far) of conflict minerals precedents was filed with the SEC albeit perhaps too late for many issuers to wholesale change course.  But still excellent for a final form check.  Intel’s Form SD can be found here and its conflict minerals report can be found here.

Perhaps somewhat surprisingly Intel makes the “DRC Conflict Undeterminable” unconstitutional confession. As I said before, only a First Amendment lawyer could find real downside here. I suspect Intel wanted the stakeholder goodwill for describing some products as DRC Conflict Free and it may have been untoward not to point out some were not.  And there is the clear communications aspect, not talking about a bunch of stuff without a conclusion.  Which of course was NAM’s point.