Per the Dodd-Frank Act, the Securities and Exchange Commission (“SEC”) issues rules relating to the use of “Conflict Minerals” within manufactured products. Conflict Minerals are tin, tantalum, tungsten and gold (also known as “3TG”). The SEC requires any SEC registrant whose products contain any 3TG (“3TG Product”) to determine whether the 3TG in the 3TG Product originated from the Democratic Republic of the Congo (“DRC”) or adjoining countries (collectively, the “DRC Region”) and, if so, whether the 3TG is “conflict free”. “3TG Conflict Free” means that the supply chain is transparent and the 3TG in 3TG Products does not benefit armed groups responsible for serious human rights abuses in the DRC Region.
Daikin Applied, as a private company, is not required to comply with the SEC’s 3TG rule. However, Daikin Applied understands the importance of sourcing conflict-free minerals and will work with our suppliers to strive towards sourcing product that is considered “3TG Conflict Free”.
Expectations of Suppliers
We expect our suppliers, at a minimum, to:
Require their suppliers to work towards achieving “3TG Conflict Free” status. To provide Daikin Applied with Conflict Mineral data when requested, identifying 3TG Product they sell to Daikin Applied and the smelter that provided the original 3TG material. Daikin Applied collaborates with a third-party compliance company called Assent Compliance to survey our suppliers on Conflict Minerals. Upon request, suppliers must complete the Conflict Mineral Reporting Template (CMRT). Assent reviews these surveys and works with non-compliant suppliers to place them on action improvement plans.
Ultimately, supply 3TG Product that is 3TG Conflict Free.