Conflict Minerals: COVID-19 in Conflict Minerals Reports — Update

May 22, 2020 | Dynda A. Thomas, National Law Review
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As discussed in a previous post, early in 2019, some companies were expressing concern that, because of the impacts of the shut-downs associated with COVID-19, certain of their suppliers might not be able to provide responses to their conflict minerals inquiries in a timely manner.  They worried that their conflict minerals disclosures for calendar year 2019 could be less robust as a result. As of May 13, 2020, based on review, none of the Form SDs filed had referred to “COVID-19,” “coronavirus” or the “pandemic. Now, through the end of May 21, 2020, with 10 days left in the filing season for calendar year 2019, based on review, five companies mentioned “COVID-19,” coronavirus” or the “pandemic” when explaining suppliers’ responses. It is possible that the COVID-19 shut-down has impacted the quality and number of supplier responses to conflict minerals inquiries for other companies that have not included discussion that in their filings.