Tantalum Tin Tungsten Gold

Transcription

1 Conflict Minerals Dodd-Frank Wall Street Reform & Consumer Protection Act Companies around the globe, including Master Lock and Waterloo, will be required to disclose the use of conflict minerals in their product. Government is concerned that sales of minerals that originate in the Democratic Republic of the Congo (DRC) may benefit armed groups in that area. Section 1502 of the 2010 Dodd-Frank Act requires companies to trace the path of the 3TG. Tantalum Tin Tungsten Gold 3 T s 1 G = 3TG

2 Step 1: 3TG Minerals are HIDDEN 3TG Minerals are HIDDEN in many different types of products Mineral Columbitetantalite (tantalum) Cassiterite (Tin) Wolframite (Tungsten) Sample Products Capacitors, ignition systems, small electronics, computer parts, video cameras, digital cameras, and jet engines or turbine blades Tin plating of steel, circuit boards, PVC, and high performance paint Fishing weights, dart tips, cell phones, golf club heads, metalworking tools, drill bits, metal wires, electrodes, contacts in lighting fixtures, electronics, electrical equipment, heating, and welding equipment. Gold Electronics and semiconductors As we launch more products with electronic platforms Regulatory Compliance becomes increasingly important

3 What Minerals and Countries are Covered? What Countries are covered: Democratic Republic of the Congo Angola Burundi Central African Republic The Republic of the Congo Rwanda South Sudan Tanzania Uganda Zambia Tantalum Tin Tungsten Gold

4 Next Steps: SEC (Securities and Exchange Commission) has adopted Conflict Mineral rules. In compliance with the Conflict Mineral rules, you should access whether your subcontractors or suppliers to your business have products that are subject to the rule, including component / finished goods both (foreign & domestic). Develop a system that can be repeatable year after year for tracking. Reminder the burden of proof is your responsibility that is being mandated by the government and will be expected for all business reporting structures to comply Certification is on our website and is available now. You will be responsible within the next couple of months to respond. Supplier Timeline coming up! This will be required for all of suppliers under the FBHS umbrella.

5 Step 2: Supplier Outreach Master Lock and / or Waterloo will provide you with a letter further explaining the Conflict Minerals requirement. This letter will ask that you determine if any of the products you supply to us incorporate conflict minerals. The letter will also ask if you do supply products containing these minerals, you confirm that the minerals did not originate in the DRC or that the minerals may have originated in the DRC or that the minerals are of an undeterminable origin. This information and form is now available on our Website.

6 Supplier Timeline Suppliers need to start analysis of which suppliers provide products that may contain 3tg minerals as soon as possible. Suppliers should then start to compile list of which of their suppliers provide products that do or may contain 3tg minerals Determine if there were any newly added suppliers/products that need to be added to list- send surveys to those suppliers Begin to follow up with your Suppliers that have not responded or provided a satisfactory response November 15: Completed website certification returned December 15: Update us with any final changes or additions. BECAUSE March 1, 2014: Master Lock/Waterloo needs to provide to FBHS your report-out for inclusion in our SEC filings

7 Letter to our Suppliers on our Website Exhibit A Master Lock/Waterloo Letter to Suppliers

8 Exhibit B & Certification EXHIBIT B Master Lock / Waterloo kwirth@mlock.com PH: (414)