Minerals originating from regions of the world where there are ongoing conflicts may end up in various products. A growing awareness of the atrocities committed in these areas of conflict, including in the process of mining certain minerals, has prompted an industry wide investigation into any supply chain tainted by these atrocities. The purpose is to report any abuses, and through disclosure, halt the sourcing of designated minerals via supply chains implicated in conflict zones.
Traceability is both the solution to the problem and the most intractable part of the problem, for example when metals are produced from scrap reclamation. In the USA, various legislative efforts culminated on July 21, 2010, when the U.S. Government signed the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), which included a provision that requires U.S. publicly traded manufacturing companies to conduct due diligence into their supply chains and disclose any products containing “Conflict Minerals” which would include tin, tantalum, tungsten and gold (known as 3TG) originating from the Democratic Republic of Congo (DRC) or adjoining countries, where atrocities have been documented during mining, refining and transportation.
As a supplier of products made from 3TG metals, we believe that no one should be harmed in our supply chain so we have established a protocol for identifying and managing the sourcing of tin, tantalum, tungsten and gold, based on the OECD guidance. We have included this protocol in our sourcing process for our suppliers to document their execution and adherence to these guidelines to remain on our Approved Vendor List.
Metal Cutting Corporation Implements our Conflict Free Minerals sourcing program using the EICC-GeSI Reporting Template. This is an international industry tool specifically designed to collect sourcing information related to Conflict Minerals. Companies are permitted to use the Template as an element of their Conflict Minerals due diligence program to assist in the verification of responsible sourcing practices, and is consistent with EICC [i] and GeSI’s[ii] related activities including the Conflict Free Smelter (CFS) program, and In-Region Sourcing efforts[iii]. Notably, for tungsten, the CFS traceability tools remain in development; and in general, the scrap exemption for all 3TG metals is a broad exception, which acknowledges that complete disclosure is impossible.
Metal Cutting Corporation is committed to enacting due diligence measures to ensure responsible sourcing. For more information regarding Conflict Free Minerals, and to download tools and resources visit http://www.conflictfreesmelter.org/.
[i] About the Electronic Industry Citizenship Coalition (EICC): The EICC was established in 2004 to improve social, economic, and environmental conditions in the global electronic supply chain through use of a standardized code of conduct. The EICC was incorporated in 2007 as an association to ensure greater awareness of the Code, and to expand its adoption across the industry. The EICC includes over 60 global electronics companies. For more information or to view the EICC Code of Conduct, see www.eicc.info.
[ii] About the Global e-Sustainability Initiative (GeSI): The Global e-Sustainability Initiative (GeSI) describes itself as dedicated to information and communication technologies (ICT) sustainability through innovation. GeSI brings together leading ICT companies – including telecommunications service providers and manufacturers as well as industry associations – and non-governmental organizations committed to achieving sustainability objectives through innovative technology. In June 2008, GeSI became a legal independent entity, an international non-profit association (AISBL) with an office near the EU institutions in Brussels, Belgium. For more information, see: www.gesi.org.
[iii] About the EICC and GeSI: See information on the EICC and GeSI Conflict-Free Smelter (CFS) Program (http://www.conflictfreesmelter.org and other information on the EICC website http://www.eicc.info/extractives.htm.)