For your interest, an update from law firm Foley Hoag’s Corporate Social Responsibility practice group:
“Looking ahead, and based on previous experience, it is most likely that the SEC will introduce a phased approach for disclosures, whereby certain initial disclosures will be required in the first reporting year that will need to be augmented in subsequent years. Many stakeholders have urged the SEC to adopt a phased approach in comments to the proposed regulations issued in December 2010.”
Read the entire update: The SEC’s Delayed Rule-Making and Implications for Corporate Conflict Minerals Reports…
Also see previously on Corp Law Report: Conflict Minerals and the Dodd-Frank Act: Long-Distance Accountability?