On August 22, 2012, the final rule regarding sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) was approved by the U.S. Securities and Exchange Commission (the SEC). The rule imposes annual reporting requirements on U.S. SEC reporting companies relating to the presence of conflict minerals in the products that they manufacture or contract to manufacture.
"Conflict minerals" refers to tantalum, tin, tungsten and gold, also known as 3TG, mined in the eastern provinces of the Democratic Republic of the Congo (DRC) and in the adjoining countries that have directly or indirectly contributed to the financing of armed groups.
Many of these armed groups are responsible for human rights violations. Specifically, some of the mines in the DRC are controlled by militias responsible for atrocities that have been committed in that country's decades-long civil war, including acts of violence toward women and children.
In addition to the DRC, countries in the DRC region include the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Howman Engineering does not directly source these materials from smelters or mines but uses components containing refined metals in the manufacturing of some of our products. As Howman Engineering does not purchase these metals directly from smelters, we must rely heavily on information that will be provided by our suppliers to determine the source and chain of custody of the metals in our products.
Howman Engineering’s reasonable due diligence includes the following:
- We require our suppliers to provide written evidence documenting that raw materials used to produce gold, tin, tantalum and tungsten, used in the materials to manufacture components and products supplied to Howman Engineering, originate from outside the “Conflict Region” or if they originate from within the “Conflict Region.”
- We have adopted the Electronic Industry Citizenship Coalition (EICC)
and the Global e-Sustainability Initiative (GeSI)
standards as a reporting tool for due diligence in conjunction with the EICC Conflict-Free Smelters Program. The EICC’s and GeSI’s work includes the Conflict Minerals Reporting Template (CMRT).
- In 2014 Howman Engineering contracted Source Intelligence
to complete a Reasonable Country of Origin Inquiry (RCOI) for those customers required to file reports with the SEC under Sections 13(a) or 15(d) of the Exchange Act. Source Intelligence engaged Howman Engineering Inc.’s suppliers to collect information about the presence and sourcing of tantalum, tin, tungsten and gold (3TG) used in the products and components supplied to Howman Engineering Inc. The program utilized the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (CMRT).
