From Elm Sustainability Partners

For conflict minerals reporting year 2018, we may see a bigger impact of last year’s SEC announcement that they will not seek enforcement for conflict minerals filings. Perhaps more “devil may care” attitude reflected in reporting. The real question for many companies this year may well be – “Who cares?”

So far this filing season, things certainly are starting out that way.

Between January 1 and February 28, 2019, four companies filed their Form SDs and Conflict Minerals Reports for reporting year 2018 – much earlier than the May 31 deadline. As they have done in previous years, Apple reported in February. They were, of course, fully prepared to file early. The other three companies, however, would have been better off waiting until the May 31 deadline and do a bit more work on their reports.

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