Conflict Minerals - Companies not subject to SEC

Question:

Why does a Company need to be 3TG compliant if it is not subject to the SEC Conflict Minerals rule?

Answer:

Companies not subject to the SEC rules disclosures are driven entirely by customer requirements, unless they fall in scope of the EU Conflict Minerals Rules, EU non-financial reporting rules, or various U.S. State government procurement rules.

 

The conflict minerals survey obligations and programs are driven by customer requests; as long as customers are still requesting, the need for a program will continue to exist.

 

Reference: https://www.sec.gov/rules/final/2012/34-67716.pdf

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