Dear Supplier:
We are writing
to you about important U.S. federal legislation that affects the automotive and
other manufacturing industries. To fully
comply with the law and forthcoming regulations, we will need your help.
Under the
Dodd-Frank Wall Street Reform Act, which was finalized in July 2010, publicly traded
companies whose products contain metals derived from minerals defined as conflict
minerals, which include tantalum, tin, tungsten, and gold, are required to
report annually to the Securities and Exchange Commission (SEC).
The new
reporting requirements are based on concerns that revenues obtained from mining
and transport of conflict minerals finance the ongoing conflict in the
Democratic Republic of Congo (DRC) and surrounding countries and the resulting
humanitarian crisis.
Under the conflict minerals regulations published by the
SEC in 2012, companies registered on the US stock exchange will be required to
report annually on conflict minerals in their products, beginning in the first
full fiscal year after the regulations are published. In our case, we will be required to file a conflict
minerals report on its use of conflict minerals for the year ended December 31,
2013 in early 2014. The reports will
also be subject to third party auditing. The requirements apply equally to U.S.
and non-U.S. suppliers. Although reporting requirements only apply
to publicly traded companies required to report to the SEC, it is expected that
these requirements will rapidly be passed through the entire industry supply
chain.
Information
required by the SEC or our customers is expected to include identifying the
country of origin for any tantalum,
tin, tungsten, and gold in our products and determining whether the conflict
minerals from the DRC are “conflict free” (that is, they do not directly or
indirectly finance armed groups through mining or mineral trading in the DRC region).
Additionally, we expect to be asked to provide details about how we obtained
and verified that information (due diligence).
We are
writing to all of our suppliers asking about the presence of conflict minerals
in the products they provide to us. To
the extent your products contain conflict minerals,
additional information will be required as to the country of origin of these
minerals.
Meeting
these requirements will be challenging and potentially costly to comply with, so
we wanted to make sure you were aware of this issue. Your cooperation will be
needed to get information from smelters/refiners in your supply chain as to
whether products contain conflict minerals that originate from conflict mines in
the DRC or adjacent countries. Only by working together will we be able to
comply with the forthcoming regulations.
To prepare
for these requirements we need you to:
a)
In
case of no conflict minerals found in your products, review the statement below
and sign it (use Template A)
b)
In
case conflict minerals are found in your products please fill up the table
below (Template B)
TEMPLATE
A - NO conflict minerals found
To the
best of my knowledge and after reasonable investigation, the undersigned hereby
certifies that none of the products we supply to ATK, VEGE de Mexico, Proformance
Powertrain Products, Yamato Powertrain Warehouse, contain any conflict
minerals.
Name:
___________________________________
Title:
____________________________________
Date:_________________
TEMPLATE
B
Conflict
minerals found
|
Product# |
Product Name: |
Material |
Supplier |
Ingredients |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(add more pages if needed)