Conflict Minerals: PDF-XChange What suppliers need to know. Covidien October 3, 2014

Transcription

1 Conflict Minerals: What suppliers need to know 1

2 CONFLICT MINERALS 101 TRAINING Agenda Understand the conflict minerals rule What we require from Covidien suppliers Responding to our questionnaire 2

3 CONFLICT MINERALS 101 TRAINING Purpose After this training, Covidien suppliers should be able to answer: What are conflict minerals? Why is Covidien concerned with tracking conflict minerals? What actions Covidien suppliers need to take? 3

4 Conflict Minerals: Overview 4

5 UNDERSTANDING THE RULE S IMPACTS What are conflict minerals? Four minerals have been defined by the U.S Securities and Exchange Commission (SEC): Tin Tungsten Tantalum Gold Minerals sourced from the DRC or adjoining country: Angola Burundi Rwanda Sudan Central African South Republic Sudan Uganda Congo Republic Democratic Republicof the Congo (DRC) Tanzania Rwanda Rwanda Burundi Burundi Congo Uganda Angola Zambia Central African Republic Zambia Republic of Tanzania 5

6 COVIDIEN S OBLIGATIONS Understanding the rule Identify 3T&G in products Covidien must determine whether its manufactured products contain conflict minerals in compliance with U.S. regulatory requirements. Conduct Reasonable Country of Origin Inquiry (RCOI) and due diligence Since Covidien products are likely to contain conflict minerals, we must determine whether the minerals originated in the covered countries through a RCOI. If we find that any of the minerals in our products originated in one of the covered countries, we must then conduct due diligence on those minerals to determine their point of origin. Reporting Once Covidien s conflict mineral use is identified, we must document our efforts on a Form SD and Conflict Minerals Report which are filed with the U.S. Securities and Exchange Commission. 6

7 Conflict Minerals: What we require from Covidien suppliers 7

8 WHAT COVIDIEN REQUIRES FROM THEIR SUPPLIERS 1. Determine if the product contains tin, tantalum, complete the of origin of source is survey tungsten, or gold (3T&G). 2. Determine the country the 3T&G 3. Determine the smelter or validate recycled or scrap 4. Access and 5. Continually update the tool as new information is received Review our conflict minerals policy: 8

9 Conflict Minerals: Filling in our survey 9

10 CONFLICT MINERALS SURVEY What is the Conflict Mineral survey tool? The Conflict Mineral survey tool is the program used by Covidien to collect the conflict minerals data from our suppliers needed to conduct due diligence and prepare our regulatory reports and filings. What do we expect from Covidien suppliers? Submit the survey in a complete, honest and timely manner to Covidien. What is a complete survey? A complete survey includes honest responses about conflict minerals in products manufactured or assembled by Covidien suppliers. For example, if the conflict mineral was added to the part before it was shipped to the Covidien supplier for assembly, the Covidien supplier should still indicate that conflict minerals are included in the product Submit information by the deadline provided in the and perform follow up with your suppliers for more information as needed 10

11 SURVEY TOOL USER GUIDE How to access the Survey Tool User Guide Click on the URL included in the to access the Survey Tool User Guide To begin the process, open the received from and click on the URL for the Survey Tool User Guide. The Survey Tool User Guide may also be accessed through the survey tool: Click the Help section in order to access the Survey Tool User Guide. 11

12 SURVEY TOOL version 3.0 Log-in page to complete the survey To begin the process, open the received from and click on the URL for the Survey Tool User Guide. The Survey Tool User Guide may also be accessed through the following link: 12

13 EXAMPLE OF APPROPRIATE RESPONSES Accepted Answer: Yes, we source from DRC smelters. AND a complete list of the smelters is provided Rejected Answer: Yes, we use DRC-free smelters. BUT a list of known smelters is not provided. minerals. Answer: No, we do not use conflict minerals Answer: Yes, we do use conflict minerals. AND a list and their origins is provided. Answer: No, we do not use conflict BUT the product requires 3T&G for its functionality. Answer: Yes, we do use conflict minerals. BUT information regarding the minerals origin is not provided. 13

14 USEFUL LINKS OECD guidelines: SEC Conflict Minerals final rule: 14

15 CONCLUSIONS Submit the survey in a complete, honest and timely manner Start early It may be necessary to perform follow-up with your suppliers to obtain information to complete the survey Thank you for taking the time to complete this training. If there are any questions, please contact us at conflict.minerals@covidien.com If there are technical issues, please contact us at Covidien_CMISurvey@ey.com 15