DuPont Statement: Conflict Minerals
The DuPont Company is committed to the responsible sourcing of minerals worldwide. The Company supports the observance of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, which promotes respect for human rights by seeking practical solutions to curb the violence associated with trade in Conflict Minerals.
- The DuPont Company will comply with the 2012 Securities and Exchange Commission (“SEC”) final rule, as mandated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), which requires publicly traded companies to disclose for each calendar year their use of Conflict Minerals in products that they manufacture or contract to manufacture. Governments around the world are promulgating similar laws and regulations related to supply chain due diligence of Conflict Minerals, and DuPont will respond accordingly.
- As a global purchaser and supplier of goods, DuPont is committed to preventing the use of Conflict Minerals that fund armed conflict in the Democratic Republic of the Congo (“DRC”) and its adjoining countries. DuPont does not directly purchase these minerals from smelters or mines and will work closely with suppliers to ensure responsible sourcing of Conflict Minerals necessary to the production or functionality of its products.
- DuPont will communicate with suppliers the Company’s goals for transparency and seek to obtain representations/certifications concerning the origin of Conflict Minerals.
- DuPont will commit to incorporate into contracts and agreements with suppliers the responsible sourcing of Conflict Minerals, and will not knowingly engage with suppliers when DuPont identifies a reasonable risk that such suppliers are sourcing from, or linked to, any entity and/or party violating basic human rights.
- DuPont will complete supplier surveys via letter and /or use of the EICC-GeSI Conflict Minerals Reporting Template.
- DuPont intends to develop further its due diligence program as additional tools become available and to review and update these Principles as necessary.
It is the responsibility of each affected DuPont business sourcing and/or selling products containing “Conflict Minerals” to implement and ensure compliance with these Principles. DuPont Sourcing has responsibility for ensuring the implementation and compliance with the Principles on a global basis by DuPont suppliers and contractors. The following Guidelines are provided to help in carrying out these responsibilities.
DuPont Guidelines on Conflict Minerals
- What is the OECD?
The Organization for Economic Cooperation and Development. The OECD has developed an internationally recognized due diligence framework to determine the source and chain of custody of Conflict Minerals, which the U.S. Department of State has endorsed.
- What is a Conflict Mineral?
Presently, the Conflict Minerals are columbite-tantalite (coltan); cassiterite ; gold and wolframite , or their derivatives, including tin, tantalum, tungsten and gold. Within the United States, the Secretary of State may later determine other minerals or their derivatives may be financing conflict in the DRC or an adjoining country.
- What are the countries adjoining the DRC?
Angola; Burundi; Central African Republic; the Republic of the Congo; Rwanda; South Sudan; Tanzania; Uganda and Zambia.
- What are the definitions of “necessary to the functionality” and “necessary to the production”?
Within the SEC’s final rule, these terms are not defined; however, generally the Conflict Mineral must be “contained” in the product, i.e., it is intentionally added, and is necessary to any of the product’s expected functions, uses or purposes.
- Is Recycled or Scrap Materials covered?
If DuPont knows or reasonably believes the Conflict Minerals came from recycled or scrap sources, no due diligence and no Conflict Minerals report are required.
- Are stockpiled materials or Conflict Minerals in inventory covered?
Conflict Minerals that were “outside the supply chain” prior to January 31, 2013, are not covered. “Outside the supply chain” applies to cassiterite, columbite-tantalite and wolframite minerals after they are smelted and gold after it is fully refined.
- Is there a de minimis standard?
The SEC final rule does not provide for a de minimis standard for trace amounts of Conflict Minerals.
- What will DuPont do if it becomes aware of a supplier whose supply chain includes metals from a conflict source?
DuPont will seek to ensure alignment throughout its supply chain and will take action as needed, including reassessing supplier relationships.