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SEC's Conflict Minerals Rules: What We Learned from 2013 and What Happens Next


Speaker(s): Beverly A. Wyckoff, Christopher T. McClure, Michael R. Littenberg
Recorded on: Oct. 24, 2014
PLI Program #: 61452

Beverly advises Dover Corporation operating companies on regulatory compliance matters, including trade compliance, cyber security, conflict minerals and government contracting.  Over the last year, she has been busy with Dover’s response to the new U.S. trade policies, including Section 232 and 301 tariffs, and preparing for Brexit.  She also oversees implementation of sanctions compliance programs across Dover’s global operating companies, and works with the companies on implementation and maintenance of key trade controls initiatives, like “know your customer” due diligence.  She provides support on geographic expansion activities, including acquisition of companies and establishing entities in new markets. 

Before joining Dover, Beverly was at Axiom Law, supporting clients on compliance programs, conflict minerals, cybersecurity, and import / export and ITAR programs. She also previously served as Vice President, General Counsel of FirstGroup America and Laidlaw Transit, the largest private transportations companies in North America, and was with Zenith Electronics Corporation, including five years as Vice President and General Counsel. She helped Zenith navigate its Chapter 11 bankruptcy and reestablish itself as a technology company through the development of an IP licensing program.  Prior to Zenith, Bev worked with a telecommunications start-up, and managed tax exempt financing with US and Japanese banks.

Bev is a graduate of Yale University and holds a law degree from the University of Miami (Florida) School of Law. She resides in Chicago with her husband and several bull terriers.   


Michael Littenberg is a partner at Ropes & Gray, in the Securities and Public Companies practice.  He is based in the New York office.

Michael advises U.S. and foreign public and private companies, investment banks, private equity funds and other private investment funds in transactional matters, including securities offerings and mergers and acquisitions. Michael also counsels U.S. public companies and foreign private issuers and their boards, board committees, special committees, executive officers and investors in connection with ongoing compliance under the U.S. securities laws, exchange requirements and governance matters.  His clients range from large well-known institutions to growing companies across every major industry.

As part of his practice, for almost 30 years, Michael has been active in advising leading public and private companies, asset managers and asset owners on ESG, corporate social responsibility and supply chain compliance matters, and he is widely viewed as one of the leading practitioners in this emerging area.  Michael is the only U.S. law firm partner ranked in Chambers Global Business and Human Rights category, has been included for multiple years in various top influencer lists relating to CSR, conflict minerals and modern slavery compliance and has been a member of numerous advisory panels on a range of CSR issues.   

In the ESG/CSR/supply chain compliance space, Michael advises clients on, among other things: compliance with a wide range of enacted, pending and proposed regulatory requirements, “soft law” instruments and industry and NGO codes of conduct, standards, frameworks and guidance;  due diligence; risk and impact assessments; structuring and implementation of tailored compliance policies, procedures, programs and codes of conduct; public benefit corporations; impact and socially responsible investing; training; benchmarking; regulatory and voluntary disclosures and other communications; stakeholder engagement; and grievance mechanisms. 


Christopher McClure leads the Midwest Forensic Practice of Crowe Horwath LLP where he assists companies and their counsel in dealing with various regulatory issues and complex disputes and investigations. Chris leads the efforts of Crowe to assist clients with the new Conflict Minerals reporting requirements under Dodd-Frank and is a frequent speaker and author. He is a CPA, CFE, experienced testifier, and has an MBA from the Kellogg School of Management. Prior to Crowe, Christopher was with Navigant Consulting and Arthur Andersen in Chicago and Texas.