Actions for the “Conflict Mineral” Disclosure Rules
“Conflict minerals” are mineral resources mined in conditions of armed conflict and human rights abuses, notably in the eastern provinces of the Democratic Republic of the Congo (“DRC”) and its surrounding countries. The profits from the extraction and trade of these conflict minerals, defined by the US State Department as gold, tin, tantalum, and tungsten, are believed to finance multiple armed groups and contribute to inhumane treatment, including human trafficking, slavery, forced labor, child labor, torture and war crimes in the conflict regions. Conflict minerals usually pass through a variety of intermediaries before reaching the final consumer.
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. The 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.
We comply with these requirements to further the humanitarian goal of ending violent conflict and prohibit using in our products gold, tin, tungsten, or tantalum from any source whose supply chain contributes to human rights abuses in the DRC or its adjoining countries. We also expect our partners to support this policy throughout the supply chain to ensure that only conflict free materials and components are used in the parts and components we procure. If we discover the use of gold, tin, tantalum, and tungsten produced in facilities that are considered to be non-conflict free, in any material, parts or components we procure, we will take appropriate actions to make our products conflict free.
- DRC countries
The Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, the Republic of Sudan, the Republic of Zambia, the Republic of Angola, the United Republic of Tanzania, the Republic of Burundi, the Republic of Rwanda, and the Republic of Uganda (according to Dodd Frank Act, Article 1502)
Specific conflict minerals subject to the regulation
||DRC and adjoining countries output in relation to global output
||Alloys for solder, etc. used to join electronic circuits and weld conducting pipes
||Approx. 15 to 20%
||Alloys used to manufacture electronic components, such as capacitors used in mobile phones, computers, video games, digital cameras, etc., as well as carbide tools and jet engine components
||Manufacturing of jewelry goods and equipment for the electronic, communication, and aerospace industries
||Lighting equipment, electronic and electrical devices, metallic products, electrodes, and contacts