Conflict Minerals: Dodd-Frank Section 1502
INTRODUCTION:
The Dodd-Frank Wall Street Reform and Consumer Protection Act, signed into law by President Obama on July 21, 2010, includes requirements for manufacturers of products containing tin, tantalum, gold, tungsten, or any other “conflict metals”. Section 1502 imposes direct SEC reporting requirements on any publicly traded companies whose products contain metals derived from conflict minerals. Conflict minerals are mined in areas such as the Democratic Republic of Congo (DRC), which provide revenue to groups committing violence in the DRC.
The Dodd-Frank Wall Street Regulation and Consumer Protection Act define “Conflict Minerals” as: columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, or any other mineral or its derivative determined by the U.S. Secretary of State to be financing conflict in the DRC or an adjoining country. Adjoining countries are defined as countries that share a border with the DRC, and include Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, Sudan, Tanzania, Uganda and Zambia. “DRC conflict free” means that the mineral may originate from one of the specified countries but has not provided finance or benefited armed groups, directly or indirectly.
THE FINAL RULE:
The final rule requires a company that files reports with the SEC under the Exchange Act disclose any “conflict minerals” that are “necessary to the functionality or production” of a product manufactured by the company.
SEKISUI SPI PRODUCTS AND CONFLICT MINERALS:
SEKISUI KYDEX is not an SEC filing company and is not required to report information regarding conflict minerals. However, through due diligence we have requested letters from our suppliers regarding conflict minerals.
SEKISUI KYDEX does not utilize the minerals tantalum, gold, or tungsten to manufacture KYDEX® Sheet products, but does utilize the mineral tin. Through our due diligence requests we have received letters from our suppliers stating that the tin source and smelters do not originate from the DRC or adjoining countries.
More information regarding the use of conflict minerals can be found on the SEC website. http://www.sec.gov/News/Article/Detail/Article/1365171562058
If you have any additional questions please contact SEKISUI KYDEX appLabTM at 1-800-682-8758 or appLab@kydex.com.
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This information supersedes all previously published data.