In response to violence and human rights violations in the mining of certain minerals from the “Conflict Region”, which is situated in the eastern portion of the Democratic Republic of the Congo (DRC) and surrounding countries, the U.S. Securities and Exchange Commission (SEC) has adopted 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.
The definition of “conflict minerals” refers to gold, as well as tin, tantalum, and tungsten (3TGs), the derivatives of cassiterite, columbite-tantalite, and wolframite, regardless of where they are sourced, processed or sold.
DSM deplores the violence in the DRC and adjoining countries and is committed to supporting responsible sourcing of conflict minerals from the region. Accordingly, DSM has adopted a conflict minerals policy according to SEC rules and regulations surrounding “conflict minerals”. DSM expects its suppliers to adopt a similar policy and to meet the expectations set out below.
DSM’s Expectations for Suppliers 3.1. Supply “DRC Conflict Free” materials.
Under DSM’s conflict mineral’s policy, suppliers are expected to supply materials to DSM that are “DRC conflict free,” which means thatany 3TGs necessary to the functionality or production of supplied materials must not directly or indirectly fund armed conflict in the DRC or adjoining countries. 3.2. Adopt conflict minerals policies.
Suppliers to DSM must adopt a policy regarding conflict minerals consistent with DSM’s policy, implement management systems to support compliance with their policy and require their suppliers to take the same steps. 3.3. Provide DSM with all relevant data regarding the conflict minerals sources.
DSM suppliers are expected to pass the CFSI public Conflict Minerals Reporting Template (link below) or another similar procedure to their suppliers until the smelter/refiner is identified. DSM should be provided with all relevant information regarding the conflict minerals sources.