The United States Congress passed legislation via The Dodd-Frank Wall Street Reform and Consumer Protection Act mandating supply chain due diligence and public disclosure relating to the sourcing of Conflict Minerals. The Securities Exchange Commission (SEC) has issued its final rule governing due diligence, disclosure and reporting requirements for Conflict Minerals from the Democratic Republic of Congo (DRC). ZincFive shares the concerns of Congress and the international business community that profits from the mining of Tin, Tantalum, Tungsten, Gold and Cobalt in the DRC or its adjoining countries may be aiding human rights abuses in portions of the DRC.
ZincFive supports the goal of the rules to end violence and human rights abuses in the DRC and surrounding countries that may be financed by proceeds from trade in these minerals. As a private company, ZINCFIVE is not required to comply with the reporting obligations of the SEC rule for disclosure as it is not required to file reports with the SEC under Sections 13(a) or 15(d) of the Securities Exchange Act of 1934. Although we are not required to submit a formal filing to the US Securities and Exchange Commission, we know that many of our customers do require Conflict Minerals Reporting Templates (CMRTs) to compile their own filings. We are working towards ensuring that our products do not contain Conflict Minerals that have been sourced from mines that support or fund conflict within the DRC or adjoining countries.
Therefore, ZincFive has taken the following actions regarding Conflict Minerals:
- We have partnered with a world class provider of environmental compliance services, to obtain current material content data on our products. Together, we work with our supply chain to routinely collect and analyze this data which enables us to determine the state of compliance for items we sell.
- We are committed to enhancing our ability to track and trace Conflict Minerals in our supply chain and ultimately not buying products and materials containing Conflict Minerals directly from conflict mines.
- We communicate to our customers about Conflict Minerals and can provide appropriate reporting upon request.
- We ask our suppliers to work towards ensuring that any Conflict Minerals contained in the products and materials supplied to ZincFive originate from Conflict Free Sources
- We engage with our suppliers so that they respond in a timely manner to our requests for evidence of compliance.
- Our suppliers’ willingness to comply with this conflict minerals initiative will be a factor in our sourcing decisions.
The information provided to our customers is provided by our suppliers through declarations and certifications.