[U]nless the current legal challenge is successful, reporting companies with necessary conflict minerals will be required to file a specialized disclosure report on or before May 31, 2014 that will include disclosure...for the initial reporting period of January 1, 2013 through December 31, 2013...If they haven’t already done so, reporting companies should begin to identify the products that they “manufacture” or “contract to manufacture” that contain necessary conflict minerals. In addition, reporting companies should create an internal team that includes senior management from various departments...to manage their compliance activities and policies. Companies that take a “wait-and-see” approach in the beginning of the new year may find themselves behind the eight ball come next year when they have to report on their conflict minerals use.