Armed groups operating in the eastern Democratic Republic of the Congo (DRC) have controlled many of the region’s mines or transit routes and have engaged in armed conflict, as well as some of the world’s worst human rights violations. Concern that proceeds from the mining of minerals have been used to fund extreme violence in that region led to a requirement in the U.S. Dodd-Frank Financial Reform Law of 2010, that U.S. publicly-traded companies must disclose any “conflict minerals” necessary to the functionality or production of products they manufacture or contract to manufacture. The conflict minerals are tin, tungsten, tantalum and gold (called the 3TG’s). Companies using conflict minerals must also disclose their supply chain inquiries to verify whether these minerals originated in the DRC or adjoining countries.
On August 22, 2012, the SEC approved the final rule on conflict minerals. All public companies must evaluate their product lines to determine whether they contain necessary conflict minerals and if so, file a Form SD by May 31 annually beginning in 2014, for products they manufacture or contract to manufacture in the year 2013. While the burden of compliance is on the public companies who manufacture those products, members of their supply chains for those products are also impacted.
Dynomax, Inc. Conflict Minerals Policy
Dynomax Inc. disapproves of the violence in the Democratic Republic of the Congo and adjoining countries and is committed to supporting responsible sourcing of conflict minerals from the region. Accordingly, Dynomax Inc. has adopted a conflict minerals policy, as part of the Supply Chain Policy. Dynomax Inc. expects its suppliers to adopt a similar policy and to meet the expectations set out below.
Expectations for Suppliers
- Supply “DRC Conflict Free” materials. Under the Dynomax Inc. conflict mineral’s policy, suppliers are expected to supply materials that are “DRC conflict free,” which means either: 1) any 3TGs necessary to the functionality or production of supplied materials must not directly or indirectly fund armed conflict in the DRC or adjoining countries, or 2) any 3TGs must be from recycled or scrap sources.
- Adopt conflict minerals policies. Suppliers must adopt a policy regarding conflict minerals consistent with the Dynomax Inc. policy, implement management systems to support compliance with their policy and require their suppliers to take the same steps.
- Send surveys to their suppliers, and complete the Dynomax Inc survey. Suppliers are expected to pass the CFSI public Conflict Minerals Reporting Template (link below) to their suppliers and successively upstream until the smelter/refiner is identified. The survey information must then be passed back down through the levels of the supply chain to the Dynomax Inc. direct supplier, who then can complete the internet-enabled version of the Conflict Minerals Reporting Template linked from this Supplier Regulatory eEnablement (SREE) website.
Dynomax Inc. encourages its suppliers to responsibly source 3TGs from the DRC and adjoining countries through smelters and refiners validated as DRC Conflict Free through the CFS or similar programs.
Link to CFSI website: http://www.conflictfreesourcing.org