In 2012 the SEC (Security and Exchange Commission) adopted a new rule pursuant to the Dodd-Frank Act requiring public companies to make disclosures of "conflict minerals" in their products.
The rule is designed to reduce the funding of armed groups engaged in conflict in the DRC (Democratic Republic of Congo) and surrounding countries by mandating additional disclosure requirements on the use and source of certain minerals whose exploitation and trade congress believed are contributing to significant human rights abuses in the DRC.
The specific minerals considered in the legislation are identified as Tungsten, Tantalum, Tin and Gold ("3 TGs").
Tribotecc GmbH has implemented a Conflict Minerals program to comply with the Conflict Minerals disclosure regulation as of 2013.
To achieve this, Tribotecc's responsibilities will include, but are not limited to:
- Determine product and supplier scope
- Conduct reasonable country of origin inquiry
- Perform due diligence
- Determine conflict status by product or product family
- Documentation Requirements
- Enhance processes to capture new products and suppliers on ongoing basis.