Sparky, The SEC doesn't need authority over private companies to impact them here. The companies that use the conflict minerals are the ones who will be doing most of the monitoring -- of their supply base. These companies need to confirm that their suppliers are not in violation of the law. It wouldn't matter whether your company is private or public; if you sell components to any of the companies overseen by the SEC you will be impacted.
Of course, you are right. The SEC does not have authority over private companies but it's a myth to think the SEC still doesn't get involved in their business. If they are big enough to get involved in any financial transactions managed by companies over which the SEC has authority then they get indirectly supervised.
Yes, but we have exhausted the 'grace period', the rule went into effect on 1 Jan and companies had until 31 Jan to conduct a review of their suppliers.
The first reporting period will be from January 1, 2013 to December 31, 2013, and the first disclosure report must be filed on or before May 31, 2014. With 'out of supply network' conflict minerals exempted prior to Jan 31, 2013.
@Bolaji: I think the companies would never be ready. It's in their interest to delay it as much as possible. I think if the regulations are imposed and a fine is imposed along side, that will serve to motivate the companies more to take quick actions.
The EU is leading efforts to exclude conflict minerals from the supply chain. The rest of the world are following (including the U.S., by the way.) I am not aware of similar legislation in China (doubt it) but two other big players in the electronics supply chain (Japan and South Korea) are probably involved.
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