As part of Section 1502 of the Dodd-Frank Wall Street Financial Reform and Consumer Protection Act (commonly referred to as the Conflict Minerals Law), all publicly-traded US companies must disclose their use of certain "conflict minerals" (tin, tantalum, tungsten and gold, often referred to as 3TG).

The trade of 3TG minerals in the Democratic Republic of the Congo and adjoining countries may be directly or indirectly financing armed groups engaged in civil war resulting in serious human rights and environmental abuses.

Our companies work to develop and maintain business relationships with reputable suppliers that share our commitment to conduct business responsibly and in compliance with applicable laws. We set expectations for suppliers through our Supplier Code of Conduct and communicate these expectations to them. To comply with the Conflict Minerals Law and promote the responsible use of 3TG in our companies' products, we expect our suppliers of goods that contain 3TG and that are incorporated into our products to:


  • have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing 3TG are not directly or indirectly financing armed groups;
  • fully comply with the Conflict Minerals Law;
  • assist our compliance efforts by providing all necessary documentation and declarations regarding the sources of 3TG in the goods supplied; and
  • communicate these requirements through their supply chain, determine the source of 3TG and report the information on the Responsible Materials Initiative's (RMI) Conflict Minerals Reporting Template.


Based on our compliance protocols, we identified no use of conflict minerals in our manufactured products in 2019 or 2020; therefore; we have not been required to file a report with the SEC since 2019. 

For more information see our SEC filings Form SD.

Commitment to the Responsible Business Alliance

As an affiliate member of the Responsible Business Alliance, the largest coalition of the world’s leading companies working together to improve corporate social responsibility in the global supply chain, we are committed to promoting the social, environmental and ethical standards set forth in the RBA Code of Conduct.