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The Importance and Implications of the SEC Conflict Minerals Inventory Exemption

Complimentary Webinar, Tuesday, February 12, 2013,
8:00am-9:00am PDT (11:00am-12:00pm EDT, 4:00am-5:00pm GMT)

Anticipation of the United States Security and Exchange Commission (SEC) Conflict Minerals Law has caused significant anxiety. Hitherto, the focus of supplier data exchange has typically been driven by ‘CSR’ initiatives. However, since August 22, 2012, when the SEC adopted the final rules concerning conflict minerals reporting, these corporate initiatives have had to assume a legal weight. You will know that the law demands that publically traded companies, working with their supply chains, must be capable of making legally binding statements regarding the sources of the metals (tin, tantalum, tungsten and gold) ‘necessary to the functionality or production’ of their products.

A critical element of the SEC final rule is the implementation of the “Inventory Exemption”, which when combined with the Form SD Filing deadline, sets the timeframe in which corporations must assess and report on their usage of conflict minerals. February 1, 2013 is a milestone marking the expiration of the Inventory Exemption and triggering an increase in the potential liability of suppliers associated with submitting an inaccurate conflict minerals declaration. Corporate supply chains must now assume that the completion and disclosure of a “Conflict-Free” certification will be relied upon by their publically traded customers, as evidence their Reasonable Country of Origin (RCOI) due diligence process. Consequently, the penalty for making a fraudulent or careless declaration has the potential to generate financial and legal liability, where little had previously existed.

Conflict Minerals reports, due diligence obligations, and data sourcing requirements will require significant commitments from a corporation’s finance, legal, IT, sourcing, supply chain, manufacturing and product stewardship departments. Moreover, the financial filing and auditing requirements will undoubtedly place significant pressure on corporate officers to pay great attention to these new legal requirements.

Foresite is pleased to invite you to attend a complementary Webinar on this legislation on Tuesday, February 12, 2013, from 8:00-9:00AM PDT (11:00-12:00PM EDT, 4:00-5:00PM GMT)

This program will include:

  • Analysis of the dominant rules associated with SEC Conflict Minerals Compliance
  • A discussion of the obligations and liabilities affecting both public and privately held companies
  • A Demonstration of Foresite’s pioneering Conflict Minerals Compliance Tools

The Webinar will be presented by Travis Miller and Graham Margetson from Foresite. As recognized experts in environmental regulatory compliance and the associated business processes, they have advised many of the largest companies in developing sound defensible regulatory compliance processes.

Registering for the Webinar:

If you would like to RSVP for this FREE seminar, please follow the link below to our registration site, https://www1.gotomeeting.com/register/713075352 and, as an informal introduction, we also invite you to visit our web site at: www.foresitecloud.com.

Thank you in advance for your time, should you have any questions, or require assistance registering, please contact Luke Owen at, (408) 377-7400, or Email:  luke.owen@foresitecloud.com

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