This paper examines conflict minerals disclosure (CMD) as mandated by the Dodd–Frank Act. We rely on a thorough content analysis conducted by the Responsible Sourcing Network on a sample of 122 firms that filed CMDs with the US Securities and Exchange Commission in 2015. We document that firms with long-term oriented incentives, a greater number of board meetings, strong corporate governance systems and inclusion in a sustainability index are associated with higher levels of CMD. Our results suggest that in the presence of enforcement leniency, both internal and external firm-specific factors affect strategic (non-)compliance with a mandatory social disclosure regime. We provide implications for supply chain managers, corporate reporters and policy-makers involved in the adoption of responsible sourcing strategies.