Conflict Minerals Policy Statement
We support ending the violence and human rights violations in the mining of certain minerals from a location described as the “Conflict Region”, which is situated in the eastern portion of the Democratic Republic of the Congo “DRC” and surrounding countries. In 2012, the U.S. Securities and Exchange Commission (“SEC”) adopted final rules to implement reporting and disclosure requirements related to “conflict minerals,” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Those rules require manufacturers who file certain reports with the SEC to disclose whether the products they manufacture or contract to manufacture contain “conflict minerals” that are “necessary to the functionality or production” of those products.
The definition of “conflict minerals” refers to gold, as well as tin, tantalum, and tungsten, which are the derivatives of cassiterite, columbite-tantalite, and wolframite, regardless of where they are sourced, processed or sold. The U.S. Secretary of State may designate other minerals as “conflict minerals” in the future. We support these requirements to further the humanitarian goal of ending violent conflict in the DRC and in surrounding countries, which has been partially financed by the exploitation and trade of “conflict minerals.”
- Support the aims and objectives of the U.S. legislation and rules on the supply of “conflict minerals.”
- Do not knowingly procure conflict minerals that originate from facilities in the “Conflict Region” that are not certified as “conflict free.”
- Undertake, and ask our suppliers to undertake, reasonable due diligence with supply chains to assure that specified metals are being sourced only from:
- Mines outside the “Conflict Region” or
- Mines and smelters which have been certified by an independent third party as “conflict free” or
- Recycled or scrap sources.
This due diligence includes having our suppliers provide written evidence documenting that raw materials used to produce gold, tin, tantalum and tungsten, used in the materials to manufacture components and products supplied to us are (i) sourced for recycled or scrap materials, (ii) originate from outside the “Conflict Region” or (iii) are sourced from mines or smelters certified as “conflict free” by an independent third party.
If we become aware of a supplier whose supply chain includes “conflict minerals” that are not conflict free, we will take actions we deem appropriate to remedy the situation in a timely manner, including reassessing our relationship with that supplier. We expect our suppliers to take similar measures with their suppliers to facilitate compliance throughout the supply chain.