CONFLICT MINERALS: CHINESE REGULATORY ADVANCES WHAT THIS MEANS FOR YOUR COMPLIANCE PROGRAM

Size: px
Start display at page:

Download "CONFLICT MINERALS: CHINESE REGULATORY ADVANCES WHAT THIS MEANS FOR YOUR COMPLIANCE PROGRAM"

Transcription

1 CONFLICT MINERALS: CHINESE REGULATORY ADVANCES WHAT THIS MEANS FOR YOUR COMPLIANCE PROGRAM

2 SUMMARY Chinese companies with conflict minerals in their supply chains, namely Tin, Tungsten, Tantalum and Gold (3TGs), are being asked to comply with a new set of due diligence guidelines developed by the China Chamber of Commerce of Metals, Minerals and Chemicals Importers and Exporters (CCCMC). INTRODUCTION The People s Republic of China is known to be a major importer of 3TGs from conflict zones in the Democratic Republic of the Congo (DRC). According to a Global Witness report 1, companies based in mainland China and Hong Kong imported all tantalum and over 80 percent of tin from Goma, North Kivu (in the eastern DRC), between January and July The same report indicates between January and December 2013, 90 percent of Goma s official exports of tin and tantalum were purchased by six companies based in mainland China and Hong Kong. Understanding Chinese companies are operating in high-risk regions, and in an attempt to improve China s reputation in this area 2, the CCCMC released a document, Guidelines for Social Responsibility in Outbound Mining Investments on October 24th, , which called for its members to proactively consider legal, ethical, social, and environmental factors in their decision-making processes and operations 4. In it, the CCCMC defines eight Social Responsibility Issues in Outbound Mining Investment 5 that Chinese companies should consider in their decision-making processes. Human rights is listed among those, as are labor issues, occupational health and safety and the environment. Section of the document specifically instructs Chinese companies to conduct risk-based supply chain due diligence in order to prevent engagement with materials that may have funded or fuelled conflict. Later on in the same section, the CCCMC says companies should adapt their existing due diligence measures to the specific needs of conflict-affected and high-risk areas and that measures should be audited by a third-party and reported publicly. Section instructs companies not to use child labor, forced or compulsory labor, and to protect the rights of employees. While the Guidelines for Social Responsibility in Outbound Mining Investments set the CCCMC s expectations, it did not provide Chinese companies the roadmap needed to meet them. What it did accomplish was to lay the groundwork for what could one day be China s first defined regulations pertaining to conflict mineral sourcing in the Democratic Republic of the Congo (DRC) and other affected areas. 1 - Global Witness. (October 2014). Tackling Conflict Minerals: How a New Chinese Initiative Can Address Chinese Companies Risks [online report, page 15]. Retrieved from China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (2015). Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains: The Guidelines [online document, page 4]. Retrieved from China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (May 2015). Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains: Project Brief [online document]. Retrieved from China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (October 2014). Guidelines for Social Responsibility in Outbound Mining Investments [online document, page 28]. Retrieved from Responsibility_in_Outbound_Mining_Operations_English_Version.pdf 5 - China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (October 2014). Guidelines for Social Responsibility in Outbound Mining Investments [online document]. Retrieved from Responsibility_in_Outbound_Mining_Operations_English_Version.pdf 2

3 A BIG STEP FORWARD The CCCMC has released a new document, The Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains (from here on referred to as the Guidelines ), that takes the direction provided in the 2014 document and builds it out into a complete set of actions companies can perform to meet those guidelines. This guidance does not vary greatly in spirit from the Organisation for Economic Cooperation and Development s (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas that many U.S. issuers are familiar with, although there is slightly more explicit emphasis on Occupational Health & Safety and the Environment. In fact, the Guidelines were modelled after and align with the OECD s guidance in order to set Chinese company due diligence to the international standard and allow for mutual recognition with existing international initiatives and legislations 6. The CCCMC states the goal of the Guidelines is to operationalize and provide detail to Clause of the Chinese Guidelines for Social Responsibility in Outbound Mining Investment by providing guidance to all Chinese companies which are extracting and/ or are using mineral resources and their related products, and are engaged at any point in the supply chain of minerals to identify, prevent and mitigate their risks of contributing to conflict, serious human rights abuses and risk of serious misconduct, as well as to observe the United Nations Guiding Principles on Business and Human Rights during the entire lifecycle of the mining project 7. This guidance does not vary greatly in spirit from the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas In order to accomplish this, the document was prepared with the help of the OECD, industry organizations and other selected stakeholders. The Guidelines are designed to support companies to achieve legal and regulatory compliance for doing business with jurisdictions that have enacted or are in the process of enacting legislation requiring due diligence for responsible supply chains of mineral resources 8. OTHER BENEFITS INCLUDE 9 : Increased ability to meet expectations of customers and markets on responsible mineral resources Enhanced Supply Chain Transparency which enables more informed and strategic decision-making Improved reputation of participating companies and of the Chinese Mining Industry Decreased disruptions in supply caused by conflict and weak governance in producing countries Provide guidance for companies wanting to undertake supply chain due diligence in natural resources other than minerals 6 - China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (October 2014). Guidelines for Social Responsibility in Outbound Mining Investments [online document]. Retrieved from Responsibility_in_Outbound_Mining_Operations_English_Version.pdf 7 - China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (2015). Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains: The Guidelines [online document, page 4]. Retrieved from China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (2015). Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains: The Guidelines [online document, page 4]. Retrieved from Ibid 3

4 WHO FALLS IN SCOPE? It is important to note compliance with these guidelines, as things stand today, is voluntary (although not explicitly stated as such within the Guidelines themselves). Although the CCCMC falls under the purview of China s Ministry of Commerce, there is no law forcing companies to comply with the Guidelines. The Guidelines apply to all Chinese companies which are extracting and/or using mineral resources and their related products, and are engaged at any point in the supply chain of minerals 10. Under the Guidelines, Chinese companies are considered to be any legal entity whose beneficial ownership fully or partially rests with a Chinese individual, or that is operating in China (including trading or mining), or is listed on a Chinese stock exchange, or is registered in China 11. The CCCMC encourages companies involved in the supply chain of other natural resources to also use the Guidelines. They plan to release additional supplementary materials and resource-specific audit protocols, providing detailed guidance for companies on how to carry out due diligence in their respective sectors. However, for now the CCCMC will prioritize the release of materials for companies dealing with conflict mineral due diligence. READING THE ROADMAP The Guidelines aim to give Chinese companies the tools they need to identify risks in their supply chain (ie. knowingly or unknowingly contributing to conflict, human rights violations and serious misconduct and to deal with those risks in an appropriate way). To facilitate this, they implemented the Five Step Risk-Based Supply Chain Due Diligence Framework. Each of the five steps are defined within the Guidelines, which also provide a list of best-practices companies should perform for each step. Step 1 calls for companies to establish and clearly communicate a policy on sourcing materials, such as 3TGs, from conflict zones. The policy should state clearly what the company s expectations are, both internally and from its suppliers, and it sets the bar for due diligence along the supply chain. In essence, Step 2 requires businesses to start asking questions about their supply chains. It calls for on-the-ground risk assessments at the production level of raw resources and probability-based risk assessment for recycled materials Establish sound risk management systems Identify and assess risk in the supply chain Design and implement a strategy to respond to identified risks Carry out independent thirdparty audits at identified risk points in the supply chain Report on the process and results of supply chain risk management 10 - China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (2015). Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains: The Guidelines [online document, page 5]. Retrieved from 11 Ibid 4

5 Step 3 helps companies decide how they should react once risks are identified in the supply chain. Options range from continuing on with an understanding of the risk involved, to changing suppliers altogether. Whatever steps are taken, further investigation and communication with suppliers, as well as local authorities and third-party organizations is called for. Step 4 is the implementation of a third-party audit process, while Step 5 best practices include publicly reporting on due diligence practices, including identified risks, in annual reports and on corporate responsibility materials (ie. on websites). As mentioned earlier, the CCCMC encourages Chinese businesses to not only comply with its DRC conflict mineral guidelines, but to apply the Five Step method to other areas of their supply chains as well. In the Guidelines, the CCCMC identifies two types of risks companies should look out for. Type 1 are risks contributing to conflict and serious human rights abuses, as defined in the OECD Due Diligence Guidance. In the Guidelines, the CCCMC states that the OECD Due Diligence Guidance is the major reference point for international standards and regulations, and therefore crucial for compliance with legal requirements for trading with markets where they apply, including with U.S.-listed companies, in the African Great Lakes Region and in European Union countries (potentially in the future 12 ). Type 2 risks go beyond the OECD s guidance to include serious misconduct, as defined in the CCCMC s Guidelines for Social Responsibility in Outbound Mining Investments. To help companies identify Type 1 and Type 2 Risks in their supply chains, the CCCMC compiled a list of warning signs. If any of these warning signs are present in the supply chain, it should trigger Steps 2 and 3 of the Five Step Framework 13. Areas witnessing sexual and gender-based violence Presence of armed conflict Areas with endemic corruption Presence of widespread violence Areas witnessing systematic discrimination against parts of the population Fragile post-conflict areas Areas witnessing widespread and systematic violations of international law, including human rights abuses Areas witnessing weak or non-existent governance and security The Guidelines encourage Chinese companies to participate in other initiatives, including international due diligence or traceability programs, and share information with business relationships China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (2015). Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains: The Guidelines [online document, page 7]. Retrieved from China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (2015). Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains: The Guidelines [online document, page 13]. Retrieved from 5

6 GETTING IT RIGHT Step 4 of the Five Step Framework involves implementation of a third-party audit process at key points along the supply chain. It is designed to assure companies are following the steps for proper due diligence when risks are identified in the supply chain. However, the CCCMC seems intent to continue to push Chinese companies further by implementing an additional certification process that goes beyond Step 4 s requirements. As with the rest of the Guidelines, pursuing certification is completely voluntary, the benefits of which would be reputational. There are three types of certifications available. To earn any one of these three certifications, companies must have their third-party audit validated by an independent oversight body against set criteria. CERTIFICATE A: Basic Responsible Sourcing Certification This is the basic responsible sourcing certification, which means companies have implemented due diligence for Type 1 risks. CERTIFICATE B: Basic Responsible Sourcing Certification (making progress) This includes the basic responsible sourcing certification, but also seeks assurance for progress on certain Type 2 risks. CERTIFICATE C: Extended Responsible Sourcing Certification This is the extended responsible sourcing certificate, assuring conformance with the Five-Step Framework s requirements for both Type 1 and Type 2 risks. THE BIG PICTURE Chinese suppliers have been known to cause problems for companies looking to perform due diligence on their own supply chains namely companies attempting to comply with the Dodd-Frank Act. These suppliers often refuse to submit CMRTs or respond to requests for information, failing to understand their role in the supply chain due diligence process. It can be hard for U.S. issuers to overcome the language barrier as they try to explain to their Chinese suppliers why certain information is required. A general lack of understanding is at the root of the problem. However, thanks to the CCCMC s efforts, that may be about to change. Despite being voluntary, the Guidelines do raise the profile of conflict mineral due diligence among Chinese companies. Not only do they provide the training and tools to comply with these guidelines, but the CCCMC itself has purposefully stated Chinese companies should participate in other conflict mineral regulations, such as Dodd-Frank 14. This should be encouraging to U.S.-based issuers with Chinese suppliers in their supply chain. It is also a positive development for European Union countries, who are in the midst of developing their own set of regulations with regards to conflict minerals in the DRC. As these initiatives become more prevalent globally, participation and compliance from traditionally difficult markets should improve. GETTING A HEAD START Although compliance with China s Guidelines is still voluntary, taking proactive measures to prepare for possible mandatory implementation should be a priority for companies that may operate in scope of the new regulations. Building and updating your compliance plan means utilizing extensive resources and potentially requires 14 - China Chamber of Commerce of Metals, Mineral and Chemicals Importers and Exporters. (2015). Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains: The Guidelines [online document, page 19]. Retrieved from 6

7 funding for new FTE or training to enhance your knowledge base. It remains an industry best-practice to implement a comprehensive compliance software solution, such as the Assent Conflict Mineral Compliance Platform, in order to manage ethical sourcing programs. It is an easy-to-use and nimble solution, allowing companies to quickly adapt in an ever-changing regulatory landscape. Assent s solution ensures that your plan is backed with expert knowledge, carried out on schedule and there is timely supply communications both upstream and downstream. Assent delivers SaaS Ethical Sourcing Compliance Services to companies that must comply with local, national and global environmental regulations. Our software division is fully supported by a team of highly experienced industry consultants providing our clients with turnkey compliance solutions. We are here to help our clients comply with ethical sourcing regulations in the most efficient and cost effective manner possible. This is achieved through SaaS automation of processes and working with clients to build efficient internal compliance programs that meet global compliance requirements. As an Assent Compliance partner, we treat your compliance goals as our own. GET STARTED NOW To find out more information, download the ebook Is Compliance Automation Right for Your Company? CHAPTERS INCLUDE: Chapter 1: Is Compliance Right for Your Company? Chapter 2: Compliance Automation Costs - Comparison Vs Full Time Equivalent Hire Chapter 3: The Business Case for Compliance is Getting Easier to Make Chapter 4: What s Next? Chapter 5: About Assent Compliance - Corporate Overview/Products DOWNLOAD NOW wp-content/uploads/2014/04/ Assent-Compliance-Automation-_-Costsand-Case-Study.pdf To build your plan, contact Assent Compliance today and receive a free demonstration of the top-rated compliance solution in the world. ABOUT THE AUTHORS Jonathan Hughes Director, Conflict Mineral Programs With over 10 years experience in the industry, Jonathan Hughes is a thought leader in ethical sourcing and Assent Compliance s leading expert on conflict mineral compliance. Samantha Kowal Customer Success Manager Samantha Kowal works with Assent s clients on software and program implementation, training, reporting and campaign planning. She is one of Assent s subject matter experts on ethical sourcing regulations. 7

8 OUR GLOBAL OFFICES CANADA (HEADQUARTERS) ASSENT COMPLIANCE 5300 Canotek Road, Suite 30 Toll Free: Ottawa ON K1J 1A4 Fax: Canada info@assentcompliance.com LONDON, UK MUNICH, GERMANY OTTAWA, ONTARIO CANADA (HQ) TAIPEI, TAIWAN NEW YORK, NEW YORK BANGALORE, INDIA KENYA (CONFLICT MINERALS) CANADA ASSENT COMPLIANCE 5300 Canotek Road, Suite 30 Ottawa ON K1J 1A4 Canada Toll Free: Fax: info@assentcompliance.com UNITED KINGDOM ASSENT COMPLIANCE Longcroft House 2-8 Victoria Avenue Bishopsgate London UK EC2M 4NS Phone: info@assentcompliance.com UNITED STATES ASSENT COMPLIANCE 244 Fifth Avenue Suite 1717 New York NY United States of America Toll Free: Fax: info@assentcompliance.com 8

Supplier Code of Conduct

Supplier Code of Conduct Supplier Code of Conduct Leading with Integrity May 2014 Introduction CSR Requirements For All Suppliers Additional Assurance Procedures Code Violations, Reporting And Review Appendices I II Acknowledgement:

More information

Supplier Code of Conduct

Supplier Code of Conduct Supplier Code of Conduct Leading with Integrity May 2014 Introduction CSR Requirements For All Suppliers Additional Assurance Procedures Code Violations, Reporting And Review Appendices I Acknowledgement:

More information

Rockwell Automation Conflict Minerals Program

Rockwell Automation Conflict Minerals Program Rockwell Automation Conflict Minerals Program Dodd-Frank Wall Street Reform & Consumer Protection Act Sec. 1502 OES Strategic Sourcing Org 2/5/2018 DIR# 10002100997 ESAP-BR023C-EN-E PUBLIC Note The information

More information

PRACTICAL IMPLEMENTATION OF DUE DILIGENCE FOR CHINESE COMPANIES

PRACTICAL IMPLEMENTATION OF DUE DILIGENCE FOR CHINESE COMPANIES PRACTICAL IMPLEMENTATION OF DUE DILIGENCE FOR CHINESE COMPANIES FINNY TANG ASIA DIRECTOR, RCS Global finny@rcsglobal.com www.rcsglobal.com 1. RCS Overview www.rcsglobal.com About RCS Global SUPPLY CHAIN

More information

Conflict Minerals Workshop - 6/24/15

Conflict Minerals Workshop - 6/24/15 Conflict Minerals Workshop - 6/24/15 IEWC Overview Global Wire, Cable and Wire Management Products Distributor Founded in 1962 22 locations, 10 countries OEM & Contract Manufacturer focus Singh Gullapalli

More information

Conflict Minerals Policy

Conflict Minerals Policy Conflict Minerals Policy INDEX 1 / INTRODUCTION 3 2 / LEGISLATIVE FRAMEWORK 3 3 / COMMITMENT 3 4 / EXPECTATIONS FOR SUPPLIERS 4 4.1 Conflict Minerals Policy Scope 4 4.2 Supplier Collaboration Requirements

More information

IS COMPLIANCE AUTOMATION RIGHT

IS COMPLIANCE AUTOMATION RIGHT 2014 IS COMPLIANCE AUTOMATION RIGHT FOR YOUR COMPANY? HOW TO TELL IN UNDER 10 MINUTES REACH RoHS PROP65 CPSIA CONFLICT MINERALS CUSTOM COMPLIANCE SOLUTIONS TABLE OF CONTENTS Chapter 1: Is Compliance Right

More information

FORM SD Specialized Disclosure Report

FORM SD Specialized Disclosure Report UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM SD Specialized Disclosure Report (Exact name of registrant as specified in its charter) Delaware 001-07201 33-0379007 (State or

More information

ESTERLINE TECHNOLOGIES CORPORATION. Conflict Minerals Report. For The Year Ended December 31, 2013

ESTERLINE TECHNOLOGIES CORPORATION. Conflict Minerals Report. For The Year Ended December 31, 2013 ESTERLINE TECHNOLOGIES CORPORATION Conflict Minerals Report For The Year Ended December 31, 2013 Esterline Technologies Corporation ( Esterline or the Company ) has prepared this report for the year ended

More information

WABCO Holdings Inc. Conflict Minerals Report. For The Year Ended December 31, 2016

WABCO Holdings Inc. Conflict Minerals Report. For The Year Ended December 31, 2016 WABCO Holdings Inc. Conflict Minerals Report For The Year Ended December 31, 2016 Background This Report for the year ended December 31, 2016 is filed pursuant to Rule 13p-1 under the Securities Exchange

More information

Guide on the Conflict Minerals Reporting Template (CMRT)

Guide on the Conflict Minerals Reporting Template (CMRT) Guide on the Conflict Minerals Reporting Template (CMRT) 1. Version Please always use the last version of the CMRT downloaded from the CFSI website http://www.conflictfreesourcing.org/conflict-minerals-reporting-template/.

More information

Harmonic Inc. Conflict Minerals Report For The Year Ended December 31, 2017

Harmonic Inc. Conflict Minerals Report For The Year Ended December 31, 2017 Harmonic Inc. Conflict Minerals Report For The Year Ended December 31, 2017 This Conflict Minerals Report ( CMR ) of Harmonic Inc. ( Harmonic ) for the calendar year ended December 31, 2017 is presented

More information

White paper Implications of metals on finance

White paper Implications of metals on finance Nordea Group Sustainable Finance February 2018 White paper Implications of metals on finance 3 Executive Summary Energy storage markets are expanding at rapid pace. The demand for metals is increasing

More information

Ball Corporation Conflict Minerals Report For the Year Ended December 31, 2014

Ball Corporation Conflict Minerals Report For the Year Ended December 31, 2014 Ball Corporation Conflict Minerals Report For the Year Ended December 31, 2014 Exhibit 1.01 Introduction This Conflict Minerals Report ( CMR ) for the year ended December 31, 2014 is presented to comply

More information

White paper Implications of metals on finance

White paper Implications of metals on finance Nordea Group Sustainable Finance February 2018 White paper Implications of metals on finance 3 Executive Summary Energy storage markets are expanding at rapid pace. The demand for metals is increasing

More information

Conflict Minerals White Paper

Conflict Minerals White Paper Qualcomm, Inc. Conflict Minerals White Paper Contributing to the Development of a Conflict Free Supply Chain May 2016 1 Qualcomm Incorporated Qualcomm Incorporated is a world leader in 3G, 4G and next-generation

More information

Taking the Conflict Out of Conflict Minerals

Taking the Conflict Out of Conflict Minerals Taking the Conflict Out of Conflict Minerals SCCE Upper Midwest Regional Conference April 26, 2013 Mike Loch Director, Supply Chain Sustainability Motorola Solutions, Inc. 1 Agenda Overview of Conflict

More information

Ethical Procurement Code

Ethical Procurement Code Ethical Procurement Code CRH Ethical Procurement Code CRH Ethical Procurement Code May 2014 1 CRH Ethical Procurement Code 1.1 Introduction and Policy Objective 1.2 Statement of Policy 1.3 Roles and Responsibilities

More information

BEST BUY CO INC FORM SD. (Specialized Disclosure Report) Filed 06/01/15

BEST BUY CO INC FORM SD. (Specialized Disclosure Report) Filed 06/01/15 BEST BUY CO INC FORM SD (Specialized Disclosure Report) Filed 06/01/15 Address 7601 PENN AVE SOUTH RICHFIELD, MN 55423 Telephone 6122911000 CIK 0000764478 Symbol BBY SIC Code 5731 - Radio, Television,

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD Specialized Disclosure Report

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD Specialized Disclosure Report UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD Specialized Disclosure Report IPG PHOTONICS CORPORATION (Exact name of registrant as specified in its charter) Delaware 001-33155

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD SPECIALIZED DISCLOSURE REPORT THERMO FISHER SCIENTIFIC INC. (Exact name of registrant as specified in its charter) Delaware

More information

NXP Semiconductors N.V. (Exact Name of the Registrant as Specified in its Charter)

NXP Semiconductors N.V. (Exact Name of the Registrant as Specified in its Charter) UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 Form SD SPECIALIZED DISCLOSURE REPORT NXP Semiconductors N.V. (Exact Name of the Registrant as Specified in its Charter) The Netherlands

More information

Elbit Systems Ltd. Conflict Minerals Report For Year Ended December 31, 2014 In Accordance with Rule 13p-1 under the Securities Exchange Act of 1934

Elbit Systems Ltd. Conflict Minerals Report For Year Ended December 31, 2014 In Accordance with Rule 13p-1 under the Securities Exchange Act of 1934 Exhibit 1.01 Elbit Systems Ltd. Conflict Minerals Report For Year Ended December 31, 2014 In Accordance with Rule 13p-1 under the Securities Exchange Act of 1934 Introduction This is the Conflict Minerals

More information

Business Relevance. Our Approach. Support for Acquiring Competence in Innovations

Business Relevance. Our Approach. Support for Acquiring Competence in Innovations ISSUES 04 Shared Growth Business Relevance As the existing competition structure among companies has expanded to competition amongst company supply chains, including partner companies, the participation

More information

A. O. Smith Corporation

A. O. Smith Corporation UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 Form SD SPECIALIZED DISCLOSURE REPORT A. O. Smith Corporation (Exact Name of Registrant as Specified in Charter) Delaware 1-475 39-0619790

More information

ASSENTCOMPLIANCE 3 MAJOR UPDATES CMRT 3.01, FORM SD TRENDS AND SMELTER INFO

ASSENTCOMPLIANCE 3 MAJOR UPDATES CMRT 3.01, FORM SD TRENDS AND SMELTER INFO 3 MAJOR UPDATES CMRT 3.01, FORM SD TRENDS AND SMELTER INFO MATT WHITTEKER MANAGER BUSINESS DEVELOPMENT 1 (866) 964-6931 MATT.WHITTEKER@.COM ABOUT ASSENT Assent Compliance delivers SaaS Environmental Compliance

More information

ESTERLINE TECHNOLOGIES CORPORATION. Conflict Minerals Report. For The Year Ended December 31, 2014

ESTERLINE TECHNOLOGIES CORPORATION. Conflict Minerals Report. For The Year Ended December 31, 2014 ESTERLINE TECHNOLOGIES CORPORATION Conflict Minerals Report For The Year Ended December 31, 2014 Esterline Technologies Corporation ( Esterline or the Company ) has prepared this report for the year ended

More information

THE MODERN SLAVERY ACT 2015 TRANSPARENCY STATEMENT FOR THE FISCAL YEAR ENDING 31 MARCH 2017

THE MODERN SLAVERY ACT 2015 TRANSPARENCY STATEMENT FOR THE FISCAL YEAR ENDING 31 MARCH 2017 THE MODERN SLAVERY ACT 2015 TRANSPARENCY STATEMENT FOR THE FISCAL YEAR ENDING 31 MARCH 2017 This statement is made on behalf of NGK SPARK PLUGS (UK) LTD pursuant to Section 54 (Part 6) of the Modern Slavery

More information

Conflict Minerals Supplier Training

Conflict Minerals Supplier Training Conflict Minerals Supplier Training Table of Content I. Overview of Conflict Minerals II. Complexity of the minerals supply chain III. Leading Industry Initiatives IV. Trimble s Conflict Minerals Policy

More information

EICC and GeSI Extractives Working Group. External Training & Outreach Jerry Meyers, Intel Fab Materials EHS

EICC and GeSI Extractives Working Group. External Training & Outreach Jerry Meyers, Intel Fab Materials EHS EICC and GeSI Extractives Working Group External Training & Outreach Jerry Meyers, Intel Fab Materials EHS Agenda Position Statement Background EICC and GeSI members Conflict Minerals and the Democratic

More information

Supplier Code of Ethics

Supplier Code of Ethics Company Policy Supplier Code of Ethics (DN.POL.06.15) Issue: 01 (December 2015) Paolo Dellachà Chief Executive Officer INDUSTRIE DE NORA S.P.A. Via Bistolfi, 35-20134 Milan Italy - ph +39 02 21291 - fax

More information

Singtel/Optus Group Supplier Code of Conduct (SCC)

Singtel/Optus Group Supplier Code of Conduct (SCC) Singtel/Optus Group Supplier Code of Conduct (SCC) Supplier Code of Conduct Page 2 Contents 1. Introduction 3 2. Corporate Governance - critical areas 4 3. Human Rights 4 3.1 General 4 3.2 Labour Rights

More information

Responsible Procurement Policy

Responsible Procurement Policy Group Procurement Responsible Procurement Policy Issue Date: 11 th January 2017 Version: 2.1 Policy Document one brandone vision Contents 1. Overview 3 2. Supplier Requirements 5 3. Added-Value Creation

More information

Belden Inc. Conflict Minerals Report For The Year Ended December 31, 2016

Belden Inc. Conflict Minerals Report For The Year Ended December 31, 2016 Belden Inc. Conflict Minerals Report For The Year Ended December 31, 2016 This report for the year ended December 31, 2016 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC FORM SD. 3M COMPANY (Exact Name of Registrant as Specified in Its Charter)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC FORM SD. 3M COMPANY (Exact Name of Registrant as Specified in Its Charter) Page 1 of 5 SD 1 a18-14241_1sd.htm SD UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549 FORM SD Specialized Disclosure Report 3M COMPANY (Exact Name of Registrant as Specified in Its

More information

Groupe PSA Responsible Purchasing Policy

Groupe PSA Responsible Purchasing Policy Groupe PSA Responsible Purchasing Policy The Groupe PSA is committed to growth founded on socially-responsible actions and behaviors in all countries in which it operates and in all fields in which it

More information

SUPPLIER CODE OF CONDUCT

SUPPLIER CODE OF CONDUCT SUPPLIER CODE OF CONDUCT FOREWORD AND SUPPLIER CERTIFICATION CTS Corporation ( CTS ), founded in 1896, has built its reputation by producing quality products as well as by adhering to the highest ethical,

More information

Bio-Techne Corporation Conflict Minerals Report For the Year Ended December 31, 2016

Bio-Techne Corporation Conflict Minerals Report For the Year Ended December 31, 2016 Bio-Techne Corporation Conflict Minerals Report For the Year Ended December 31, 2016 Introduction This Conflict Minerals Report for Bio-Techne Corporation ( Bio-Techne, the Company, we, or our ) is provided

More information

Conflict Minerals Supplier Training

Conflict Minerals Supplier Training Conflict Minerals Supplier Training 2015 Table of Content I. Overview of Conflict Minerals II. Complexity of the minerals supply chain III. Leading Industry Initiatives IV. Trimble s Conflict Minerals

More information

VARIAN MEDICAL SYSTEMS, INC. Supplier Code of Conduct

VARIAN MEDICAL SYSTEMS, INC. Supplier Code of Conduct VARIAN MEDICAL SYSTEMS, INC. Supplier Code of Conduct VARIAN MEDICAL SYSTEMS, INC. Supplier Code of Conduct This Supplier Code of Conduct, in conjunction with our Code of Conduct, outlines the requirements

More information

FORM SD Specialized Disclosure Report

FORM SD Specialized Disclosure Report UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549 FORM SD Specialized Disclosure Report PLY GEM HOLDINGS, INC. (Exact Name of Registrant as Specified in Its Charter) Delaware 001-35930

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D. C FORM SD Specialized Disclosure Report FORD MOTOR COMPANY

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D. C FORM SD Specialized Disclosure Report FORD MOTOR COMPANY UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D. C. 20549 FORM SD Specialized Disclosure Report FORD MOTOR COMPANY (Exact name of registrant as specified in its charter) Delaware (State

More information

Volkswagen Group requirements regarding sustainability in its relationships with business partners (Code of Conduct for Business Partners).

Volkswagen Group requirements regarding sustainability in its relationships with business partners (Code of Conduct for Business Partners). Volkswagen Group requirements regarding sustainability in its relationships with business partners (Code of Conduct for Business Partners). I. Preface The following requirements define the Volkswagen Group

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD SPECIALIZED DISCLOSURE REPORT SCI ENGINEERED MATERIALS, INC. (Exact name of registrant as specified in its charter) Commission

More information

Responsible Supply Chain

Responsible Supply Chain Responsible Supply Chain Management System With social responsibility in procurement, including consideration for the environment and human rights, being expected from society, we at Panasonic are working

More information

The OECD Due Diligence Guidance for Conflict-Free Mineral Supply Chains

The OECD Due Diligence Guidance for Conflict-Free Mineral Supply Chains The OECD Due Diligence Guidance for Conflict-Free Mineral Supply Chains Tyler Gillard Legal Expert OECD Investment Division Background OECD began work on due diligence for conflict-free supply chains in

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C FORM SD SPECIALIZED DISCLOSURE REPORT

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C FORM SD SPECIALIZED DISCLOSURE REPORT UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM SD SPECIALIZED DISCLOSURE REPORT AMERICAN AXLE & MANUFACTURING HOLDINGS, INC. (Exact Name of Registrant as Specified in Its

More information

Partnering on Sustainability:

Partnering on Sustainability: Partnering on Sustainability: How to Overcome Barriers and Establish a Sound Sustainable Purchasing Leadership Council 2015 Summit Christina Simon Corporate Program Manager, Supply Chain Sustainability

More information

An Overview of the Responsible Minerals Initiative (RMI) for Supply Chain and Compliance Professionals ADVANCED SUPPLY CHAIN COMPLIANCE SERIES

An Overview of the Responsible Minerals Initiative (RMI) for Supply Chain and Compliance Professionals ADVANCED SUPPLY CHAIN COMPLIANCE SERIES An Overview of the Responsible Minerals Initiative (RMI) for Supply Chain and Compliance Professionals ADVANCED SUPPLY CHAIN COMPLIANCE SERIES January 11, 2018 1 About Michael Littenberg Michael Littenberg

More information

Conflict-Free Sourcing Initiative

Conflict-Free Sourcing Initiative Conflict-Free Sourcing Initiative Overview & update The Conflict-Free Sourcing Initiative www.conflictfreesourcinginitiative.org @EICCoalition @GeSIConnect Roadmap CFSI Overview Conflict-Free Smelter Program

More information

Sustainable Supply Chain Support and Management

Sustainable Supply Chain Support and Management 42 Samsung SDI Sustainability Report 2016 High Material Issue 07 Sustainable Supply Chain Support and Management Samsung SDI's main supply chain is a partner company that supplies raw materials for products

More information

Exhibit I. Introduction

Exhibit I. Introduction Exhibit 1.01 CONFLICT MINERALS REPORT OF Clearfield, Inc. IN ACCORDANCE WITH RULE 13p-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934 FOR THE REPORTING PERIOD FROM JANUARY 1 TO DECEMBER 31, 2014 I. Introduction

More information

SUPPLIER EVALUATION A. QUALITY SYSTEM. 1. Management (Note: Please select all that apply. For those that do not apply, please respond with N/A) Yes

SUPPLIER EVALUATION A. QUALITY SYSTEM. 1. Management (Note: Please select all that apply. For those that do not apply, please respond with N/A) Yes SUPPLIER EVALUATION Company Name: Address: City, State or Province, Postal Code, Country: Email Address: Phone #: Fax #: Contact Name: Date: 1. Management (te: Please select all that apply. For those that

More information

Magnetek, Inc. (Exact Name of Registrant as Specified in Charter)

Magnetek, Inc. (Exact Name of Registrant as Specified in Charter) UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 Form SD SPECIALIZED DISCLOSURE REPORT Magnetek, Inc. (Exact Name of Registrant as Specified in Charter) Delaware 001-10233 95-3917584

More information

United States Securities and Exchange Commission Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT

United States Securities and Exchange Commission Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT United States Securities and Exchange Commission Washington, D.C. 20549 FORM SD SPECIALIZED DISCLOSURE REPORT HollyFrontier Corporation (Exact name of registrant as specified in its charter) Delaware 1-3876

More information

COOPER TIRE & RUBBER COMPANY GLOBAL SUPPLIER CODE OF CONDUCT

COOPER TIRE & RUBBER COMPANY GLOBAL SUPPLIER CODE OF CONDUCT COOPER TIRE & RUBBER COMPANY GLOBAL SUPPLIER CODE OF CONDUCT SUPPLIER CODE OF CONDUCT I. OVERVIEW Cooper Tire & Rubber Company ( Cooper ) recognizes that the quality of our Supplier relationships affects

More information

CONFLICT MINERALS REPORT Sypris Solutions, Inc.

CONFLICT MINERALS REPORT Sypris Solutions, Inc. CONFLICT MINERALS REPORT Sypris Solutions, Inc. This Conflict Minerals Report ( Report ) of Sypris Solutions, Inc. ( Sypris or we or our ) for the year ended December 31, 2014 is presented to comply with

More information

NEENAH, INC. ETHICAL PURCHASING POLICY. This Policy was issued by Michael D. Woody, Director Strategic Sourcing on December 1, 2011

NEENAH, INC. ETHICAL PURCHASING POLICY. This Policy was issued by Michael D. Woody, Director Strategic Sourcing on December 1, 2011 NEENAH, INC. ETHICAL PURCHASING POLICY This Policy was issued by Michael D. Woody, Director Strategic Sourcing on December 1, 2011 Revised May 2017 Ethical Purchasing Policy Sustaining an ethical procurement

More information

Apple Statement on Efforts to Combat Human Trafficking and Slavery in Our Business and Supply Chains

Apple Statement on Efforts to Combat Human Trafficking and Slavery in Our Business and Supply Chains Apple 2016 Statement on Efforts to Combat Human Trafficking and Slavery in Our Business and Supply Chains Background Apple¹ is committed to treating everyone in our business and supply chain with the dignity

More information

CONFLICT MINERALS ALL IS NOT LOST (FOR 2013)

CONFLICT MINERALS ALL IS NOT LOST (FOR 2013) CONFLICT MINERALS ALL IS NOT LOST (FOR 2013) WSP USA - Amy Couch Schultz - Tord Dennis - Revati Pradhan-Kasmalkar Note: The information included in this presentation is provided for educational purposes

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD SPECIALIZED DISCLOSURE REPORT THE TIMKEN COMPANY (Exact Name of Registrant as Specified in its Charter) Ohio (State or Other

More information

FORM SD Specialized Disclosure Report

FORM SD Specialized Disclosure Report UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD Specialized Disclosure Report (Exact name of registrant as specified in its charter) Delaware 1-7724 39-0622040 (Commission

More information

Supplier Code of Conduct

Supplier Code of Conduct Supplier Code of Conduct The advancement of science around the world depends on scientists ability to access the tools they need in a timely and cost-efficient manner. Sigma-Aldrich is committed to meeting

More information

SUPPLIER CODE OF CONDUCT

SUPPLIER CODE OF CONDUCT Feb 2016 SUPPLIER CODE OF CONDUCT Berry Plastics Corporation, its affiliates, divisions, and subsidiaries ( Berry ) strive to conduct business in a responsible manner. As we expand our business activities

More information

Conflict Minerals An evaluation of the Dodd-Frank Act and other resourcerelated Andreas Manhart Brussels,

Conflict Minerals An evaluation of the Dodd-Frank Act and other resourcerelated Andreas Manhart Brussels, Conflict Minerals An evaluation of the Dodd-Frank Act and other resourcerelated measures Andreas Manhart Brussels, 03.09.2013 Our Profile Oeko-Institut is a leading European research and consultancy institute

More information

Conflict Minerals Reporting Training. Module 1: Introduction To Conflict Minerals Reporting

Conflict Minerals Reporting Training. Module 1: Introduction To Conflict Minerals Reporting Conflict Minerals Reporting Training Module 1: Introduction To Conflict Minerals Reporting SLIDE 2 Conflict Minerals Training Modules Module 1 Background on the Conflict Minerals legislation Overview of

More information

OECD Gap Analysis: BSP

OECD Gap Analysis: BSP BSR REVIEW OECD Gap Analysis: MAY 2016 Introduction, Objectives, and Brief Description The Better Sourcing Program ( or the Program ) requested that BSR (Business for Social Responsibility) conduct an

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C Form SD SPECIALIZED DISCLOSURE REPORT. Tenneco Inc.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C Form SD SPECIALIZED DISCLOSURE REPORT. Tenneco Inc. UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 Form SD SPECIALIZED DISCLOSURE REPORT Tenneco Inc. (Exact name of registrant as specified in its charter) Delaware 1-12387 76-0515284

More information

Conflict minerals The automotive perspective. November 2014

Conflict minerals The automotive perspective. November 2014 Conflict minerals The automotive perspective November 2014 Contents The current automotive environment 3 The conflict minerals environment and the automotive impact 4 The road ahead 6 How can Deloitte

More information

COLFAX CONFLICT MINERALS COMPLIANCE: PROGRAM OVERVIEW AND Q&A SESSION

COLFAX CONFLICT MINERALS COMPLIANCE: PROGRAM OVERVIEW AND Q&A SESSION COLFAX CONFLICT MINERALS COMPLIANCE: PROGRAM OVERVIEW AND Q&A SESSION Mark Allegretti Director, Implementation & Strategic Integration Organization: Corporate Legal / Global Sourcing Contact Information:

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT HARRIS CORPORATION

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT HARRIS CORPORATION UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD SPECIALIZED DISCLOSURE REPORT HARRIS CORPORATION (Exact name of the registrant as specified in its charter) Delaware 1-3863

More information

Harley-Davidson, Inc.

Harley-Davidson, Inc. UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 Form SD SPECIALIZED DISCLOSURE REPORT Harley-Davidson, Inc. (Exact Name of Registrant as Specified in Charter) Wisconsin 1-9183 39-1382325

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT AVON PRODUCTS, INC.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM SD SPECIALIZED DISCLOSURE REPORT AVON PRODUCTS, INC. AVP SD 5/26/2016 Section 1: SD (SD) UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD SPECIALIZED DISCLOSURE REPORT AVON PRODUCTS, INC. (Exact name of registrant as specified

More information

Supplier Code of Conduct

Supplier Code of Conduct Supplier Code of Conduct CRH Supplier Code of Conduct Leading with Integrity CRH Supplier Code of Conduct CRH Supplier Code of Conduct Introduction CSR Requirements For All Suppliers Additional Assurance

More information

C&J Energy Services Conflict Minerals Policy, Compliance Program & Due Diligence Framework for Reasonable Country of Origin Inquiry

C&J Energy Services Conflict Minerals Policy, Compliance Program & Due Diligence Framework for Reasonable Country of Origin Inquiry 1 C&J Energy Services, Inc. Conflict Minerals Report for the Year Ended December 31, 2016 in Accordance with Rule 13p-1 under the Securities Exchange Act of 1934 This is the Conflict Minerals Report (

More information

Request for Applications: Independent Mineral Chain Auditor for the International Conference on the Great Lakes Region (ICGLR)

Request for Applications: Independent Mineral Chain Auditor for the International Conference on the Great Lakes Region (ICGLR) Request for Applications: Independent Mineral Chain Auditor for the International Conference on the Great Lakes Region (ICGLR) 1. Background 1.1. ICGLR Overview The International Conference on the Great

More information

Market Entry Standard for Artisanal and Small-scale Producers of Gold and Associated Precious Metals Terms of Reference

Market Entry Standard for Artisanal and Small-scale Producers of Gold and Associated Precious Metals Terms of Reference July 25, 2017 Market Entry Standard for Artisanal and Small-scale Producers of Gold and Associated Precious Metals Terms of Reference Introduction Note: The denomination Market Entry Standard is a working

More information

Table 2: Summary of activities undertaken to demonstrate compliance

Table 2: Summary of activities undertaken to demonstrate compliance Refiner Compliance Report (Prepared for ISAE 3000 engagements) The LBMA Responsible Gold Guidance has been established for Good Delivery Refiners to adopt high standards of due diligence in order to combat

More information

Apple Statement on Efforts to Combat Human Trafficking and Slavery in Our Business and Supply Chains

Apple Statement on Efforts to Combat Human Trafficking and Slavery in Our Business and Supply Chains Apple 2017 Statement on Efforts to Combat Human Trafficking and Slavery in Our Business and Supply Chains Background Apple¹ is committed to treating everyone in our business and supply chain with dignity

More information

Are you ready for conflict minerals reporting?

Are you ready for conflict minerals reporting? Are you ready for conflict minerals reporting? Insights for US reporters and their suppliers By 31 May 2014, all SEC registrants that use conflict minerals in their manufactured products will need to disclose

More information

Responsibilities to Suppliers

Responsibilities to Suppliers Responsibilities to Suppliers Casio procures various materials from a large number of suppliers in and outside Japan. In order to develop long-term business relationships based on its Procurement Policies,

More information

Valmet guidance on restricted materials in products 1/8

Valmet guidance on restricted materials in products 1/8 Valmet guidance on restricted materials in products 1/8 1 Introduction Legislation in various countries is limiting the use of potentially dangerous substances. Potentially dangerous substances are chemicals

More information

CONFLICT MINERALS REPORT (For the reporting period from January 1, 2016 to December 31, 2016)

CONFLICT MINERALS REPORT (For the reporting period from January 1, 2016 to December 31, 2016) CONFLICT MINERALS REPORT (For the reporting period from January 1, 2016 to December 31, 2016) INTRODUCTION This Conflict Minerals Report (the Report ) of Versum Materials, Inc. (the Company ) has been

More information

Steelcase Supplier Code of Conduct PUBLISHED MARCH 2013, REVISED MARCH 2017

Steelcase Supplier Code of Conduct PUBLISHED MARCH 2013, REVISED MARCH 2017 Steelcase Supplier Code of Conduct PUBLISHED MARCH 2013, REVISED MARCH 2017 Our Vision At Steelcase we believe that businesses can be successful, in fact can thrive, only where there exists a healthy balance

More information

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

Conflict Minerals: PDF-XChange What suppliers need to know. Covidien October 3, 2014 Conflict Minerals: What suppliers need to know 1 CONFLICT MINERALS 101 TRAINING Agenda Understand the conflict minerals rule What we require from Covidien suppliers Responding to our questionnaire 2 CONFLICT

More information

Veoneer - Business Conduct and Ethics for Suppliers

Veoneer - Business Conduct and Ethics for Suppliers Veoneer - Business Conduct and Ethics for Suppliers 2018 Ver. 1.0 1 July 31,2018 Business conduct and Ethics for Suppliers - Training Objectives Communicate Veoneer s purpose Explain why we care about

More information

Supplier Code. Version 1.0

Supplier Code. Version 1.0 Supplier Code Version 1.0 Effective May 3, 2017 1 TABLE OF CONTENTS Supplier Code of Conduct... 3 Preface... 3 Scope... 3 Management, Monitoring and Evaluation... 3 Section 1: Ethical Practices... 4 Conflict

More information

Conflict Minerals in the context of Sustainable and Responsible Sourcing and Extraction of Raw Materials

Conflict Minerals in the context of Sustainable and Responsible Sourcing and Extraction of Raw Materials Conflict Minerals in the context of Sustainable and Responsible Sourcing and Extraction of Raw Materials EU-LATIN AMERICA MINING & EXPLORATION CONVENTION AND TRADE SHOW METS 2018 10 12 April 2018, Madrid,

More information

MELLANOX TECHNOLOGIES, LTD. (Exact Name of Registrant as Specified in Its Charter)

MELLANOX TECHNOLOGIES, LTD. (Exact Name of Registrant as Specified in Its Charter) UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD SPECIALIZED DISCLOSURE REPORT Commission File No. 001-33299 MELLANOX TECHNOLOGIES, LTD. (Exact Name of Registrant as Specified

More information

INPUT ON CORPORATE HUMAN RIGHTS DUE DILIGENCE

INPUT ON CORPORATE HUMAN RIGHTS DUE DILIGENCE INPUT ON CORPORATE HUMAN RIGHTS DUE DILIGENCE Sarah Carpenter Senior Business & Human Rights Analyst Assent Compliance sarah.carpenter@assentcompliance.com INPUT ON CORPORATE HUMAN RIGHTS DUE DILIGENCE

More information

LITTELFUSE SOCIAL RESPONSIBILITY

LITTELFUSE SOCIAL RESPONSIBILITY 1 LITTELFUSE LITTELFUSE Littelfuse has implemented social responsibility programs that apply across our organization and to our suppliers. These programs are based on our core company values and are integrated

More information

Our general approach to prevent and address human rights abuses

Our general approach to prevent and address human rights abuses Statement from Daimler 29/08/16 Despite having been able to confirm that none of the companies which were named by Amnesty International are direct suppliers of our company, we nevertheless take the issues

More information

FIAT CHRYSLER AUTOMOBILES N.V.

FIAT CHRYSLER AUTOMOBILES N.V. FIAT CHRYSLER AUTOMOBILES N.V. FORM SD (Specialized Disclosure Report) Filed 05/31/17 Telephone 011 44 20 7766 0311 CIK 0001605484 Symbol FCAU SIC Code 3711 - Motor Vehicles and Passenger Car Bodies Industry

More information

GLOBAL COMPACT COMMUNICATION ON PROGRESS

GLOBAL COMPACT COMMUNICATION ON PROGRESS GLOBAL COMPACT COMMUNICATION ON PROGRESS 1 Introduction The United Nations Global Compact is rooted in the desire to promote a sustainable global economy, in full respect of human rights, labour rights,

More information

THE DOW CHEMICAL COMPANY

THE DOW CHEMICAL COMPANY UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD Specialized Disclosure Report THE DOW CHEMICAL COMPANY (Exact name of registrant as specified in its charter) Delaware 1-3433

More information

Conflict Minerals: The Tipping Point for Compliance?

Conflict Minerals: The Tipping Point for Compliance? Conflict Minerals: The Tipping Point for Compliance? CIMdata Commentary Key takeaways: Companies developing products across a wide range of industries face increasing complexity in their products and value

More information

Questions Received re: PPA RfP for Independent Assessment of Closed Pipe Supply Chain Programs

Questions Received re: PPA RfP for Independent Assessment of Closed Pipe Supply Chain Programs Questions Received re: PPA RfP for Independent Assessment of Closed Pipe Supply Chain Programs Definition of Assessment and Criteria for Assessing Programs 1. The RFP mentions that the PPA is seeking an

More information

DUE DILIGENCE PLAN 0. DECLARATION OF COMPLIANCE TO CONFLICT-FREE MINERAL POLICY. 1. Establishing Robust Internal Risk Management System.

DUE DILIGENCE PLAN 0. DECLARATION OF COMPLIANCE TO CONFLICT-FREE MINERAL POLICY. 1. Establishing Robust Internal Risk Management System. DUE DILIGENCE PLAN 0. DECLARATION OF COMPLIANCE TO CONFLICT-FREE MINERAL POLICY The Company declares that it will comply to its Conflict-Free Mineral Policy which adheres strictly to OECD Guidance on Sourcing

More information

THE DOW CHEMICAL COMPANY (Exact name of registrant as specified in its charter)

THE DOW CHEMICAL COMPANY (Exact name of registrant as specified in its charter) UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD Specialized Disclosure Report THE DOW CHEMICAL COMPANY (Exact name of registrant as specified in its charter) Delaware 1-3433

More information

COMMUNICATION ON PROGRESS

COMMUNICATION ON PROGRESS 2009 COMMUNICATION ON PROGRESS COMMUNICATION ON PROGRESS 2009 PRINCIPLE 1: Businesses should support and respect the protection of internationally proclaimed human rights. We support and respect human

More information