The number of filings for calendar year 2013 (approximately 1,300) suggests that the SEC’s and business groups’ initial projection of impacted companies (6,000) was overestimated and/or some potential reporters may have failed to identify the applicability of conflict mineral reporting to their operations. Initial filings also make clear that companies will need the additional time afforded under the transition period of the rule to work with their suppliers to determine the origin of the conflict minerals in their products. Many companies have complex supply chains, and a commitment from suppliers and the coordination of global organizations will be necessary for companies to assess their own systems, processes, representations and results. As companies pay increasing attention to supply chain monitoring and reporting, the information presented in this report may help serve as a guide to 3TG disclosure, facilitating an assessment of how companies compare to others in the marketplace.

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