Late last week, a shareholder activist filed, what is believed to be, the first proxy access resolution for this proxy season. The target of the proposal, MEMC Electronic Materials, Inc., is an S&P 500 company that manufactures and sells wafers and related products to the semiconductor and solar industries. As discussed in a previous blog
November 2011
SEC May Have Grossly Underestimated the Costs of Proposed Conflict Mineral Disclosure Rules
By Gustav L. Schmidt on
Posted in Disclosure Guidance
Section 1502 of the Dodd-Frank Act mandates the SEC to adopt rules requiring reporting companies to disclose whether certain minerals used in production chains originate from the Democratic Republic of the Congo or its neighboring countries. Minerals sourced from these areas of central Africa often fund militia and other military groups’ operations which have exacerbated…