Dynda A. Thomas

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Cross-Post from the Conflict Minerals Law: Countdown to EU Conflict Minerals Regulation (7 Months)

This is a Cross-post from the Conflict Minerals Law blog.   Please contact Dynda A. Thomas with any questions.  In less than 7 months, the EU conflict minerals regulation will take full effect, and importers into the European Union of certain threshold amounts of tin, tantalum, tungsten and gold (3TG) and of metals containing 3TG will … Continue Reading

The EU Conflict Minerals Regime

Responsible sourcing is a vital consideration for supply chain professionals, however, sourcing valuable minerals from conflict-affected and high-risk areas is one of the most challenging supply chain concerns.  Importers of conflict minerals must meet the obligations of EU Regulation 2017/821, the Conflict Minerals Regulation, requiring third-party audits and disclosures about supply chain due diligence. Our resident conflicts … Continue Reading

Cross-post from Conflict Minerals Law Blog: Conflict Minerals Report No Longer Required? Wait — Not So Fast

Now that the matter has been remanded to the Commission, Acting Chairman Piwowar and the SEC Division of Corporation Finance have both issued public statements on the D.C. Court of Appeals decision reaffirming its prior holding that the Conflict Minerals rule “violate[s] the First Amendment to the extent the statute and rule require regulated entities to … Continue Reading

Cross-post from Conflict Minerals Law Blog: European Conflict Minerals Regulation — Details On What EU Importers Must Do

We’ve published another update on conflict minerals rules, this time regarding the EU regulation.  Click below to read about the proposed EU conflict minerals regulation, some similarities it has with the US rule, and importantly what EU importers need to know to comply with its requirements. European Conflict Minerals Regulation — Details On What EU … Continue Reading

Responsible Sourcing For Garment and Footwear Manufacturers, Brands, and Retailers – New Guidance from the OECD

On February 8, 2017, the Organisation for Economic Co-operation and Development (OECD) issued its Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector.  The Guidance promotes a framework of actions that enterprises in this sector can use to address and reduce the negative human rights impacts of their business activities.  It’s … Continue Reading

New Slavery and Human Trafficking Statements: Coming into Force Today

The new obligation on commercial organisations over a certain size to publish a slavery and human trafficking statement has come into force today. There will, however, be transitional provisions to allow affected businesses sufficient time to understand the new requirements and produce a statement. Businesses with a year-end date on or after 31 March 2016 … Continue Reading

See Our Interview Concerning California Transparency Lawsuits in Inside Counsel Magazine!

Last week, we had the great honor of talking with Amy Stickel at Inside Counsel Magazine about the recently filed California lawsuits based on companies’ California Transparency in Supply Chain Disclosure Act statements and/or their internal supply chain policies.  Previously, we’ve written about these lawsuits in this blog here and here. With Amy, we discussed how these lawsuits … Continue Reading

Litigation Fallout From All This Supply Chain Transparency Legislation (Or, These Things Have Teeth!) (Or, The Cycle of Misfortune)

In previous posts, we’ve talked about emerging legislation designed to increase visibility and transparency in supply chains to bring about desirable social ends.  We’ve discussed, for instance, the California Transparency in Supply Chains Act and the UK Modern Slavery Act, both of which require companies to disclose their efforts to eradicate slavery from their supply … Continue Reading
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