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Conflict Minerals Regulations – Notification & Certification


On August 22, 2012 the US Securities and Exchange Commission (SEC) adopted final rules implementing Section 1502 of the Dodd-Frank Act. The Act imposes requirements relating to “Conflict Minerals”. Specifically, section 1502 of the Act imposes Security and Exchange Commission (SEC) reporting requirements upon publicly-traded companies whose products contain metals derived from minerals defined as “Conflict Minerals” which include tin, gold, columbite-tantalite (tantalum), cassiterite, wolframite (tungsten), and their derivatives. The intent of the provision is to reduce or eliminate the flow of the funds derived particularly from the sale of these minerals that are believed to be supporting the various warring factions in the Democratic Republic of Congo (DRC) or an adjoining country. Adjoining countries are those countries that share an internationally recognised border with the DRC.

The legislation requires SEC-registered companies to disclose annually to the SEC whether any “Conflict Minerals” used in products they manufacture or contract to manufacture originated in the DRC or an adjoining country and make that disclosure on the company’s publicly available website. These requirements apply equally to U.S. and non-U.S. suppliers. In addition, information reporting may be required by lower tier suppliers of companies that are not SEC-registrants if they are supplying, though the supply chain, to manufacturing companies that are themselves SEC registrants.

To learn more about the U.S Legislation and “Conflict Minerals,” please consult the SEC website at: http://www.sec.gov/rules/final/2012/34-67716.pdf

As due diligence Charcroft Electronics has been in contact with all its key suppliers; each confirming that to the best of their knowledge they do not use ‘conflict minerals’ in their production processes. We pass this information on to our customer base in good faith. However as you can appreciate this for some is a time consuming task as they are obligated to drill down through the potentially various tiers of their supply chain. Charcroft therefore remains in regular contact with its suppliers on the subject and maintains a register of responses received to date. Should at any time we receive adverse information this will be passed on to those customers who have bought such products from us. However should at any time you wish verify the latest information we have available please do not hesitate to contact your Charcroft Sales contact.

We will continue to further develop this process if and when the EU Commission introduce their own rules: http://www.capacitorindustry.com/european-conflict-minerals-legislation-expected-by-the-end-of-2013