Conflict-Free Sourcing Initiative

The standard list of our company's conflict-free smelter assessment program comprises smelters that have undergone independent third-party evaluation and have been verified as compliant with the requirements for conflict-free smelters under the "conflict minerals" provisions of the U.S. Dodd-Frank Act.

It should be noted that conflict-free smelters are recognized through the EICC-GeSI Conflict-Free Smelter (CFS) Program or other globally recognized certification initiatives.

In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act, which includes provisions requiring companies to trace and disclose the origin of conflict minerals—specifically tin, tantalum, tungsten, and gold—sourced from the Democratic Republic of the Congo (DRC) and adjoining countries.

The U.S. Securities and Exchange Commission (SEC) subsequently issued final rules regarding the disclosure of conflict mineral sourcing by publicly listed companies (available at: http://www.sec.gov/rules/final/2012/34-67716.pdf).  These rules reference the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (http://www.oecd.org/dataoecd/62/30/46740847.pdf), which provides a framework for supplier engagement, due diligence processes, and responsible sourcing management systems.

For additional information, please refer to the Conflict-Free Smelter (CFS) Program website (www.conflictfreesmelter.org) and related resources available at www.eicc.info/extractives.htm.

Thank you for your interest in the Conflict-Free Sourcing Initiative. To gain access to the Conflict-Free Smelter Program list of compliant smelters and refiners, and the Conflict Minerals Reporting Template and Dashboard.