Conflict Minerals Policy

Conflict Minerals” refers to specific minerals mined in the eastern provinces of the Democratic Republic of the Congo (DRC) and in the adjoining countries where the revenues from these minerals may be directly or indirectly financing armed groups engaged in civil war resulting in serious social and environmental abuses.

In July 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) was signed into law in the U.S. As adopted, the Dodd-Frank Act required the U.S. Securities and Exchange Commission (the “SEC”) to promulgate regulations requiring publicly traded companies to disclose their use of Conflict Minerals and its origins, and if from covered regions, disclose whether or not the minerals are ‘conflict-free’. The specific minerals addressed by the Dodd-Frank Act are Cassiterite, Columbite-Tantalite, Wolframite, gold and derivatives of these minerals. In August 2012, the SEC adopted the necessary regulations, which, among other things, require publicly traded companies to conduct due diligence on their supply chain and to disclose information regarding Conflict Mineral usage, if any.

ACTIA Automotive fully supports the intent of this legislation to eliminate the social and environmental harm brought about by the use of Conflict Minerals and any funding that supports armed groups in the DRC region.

The supply chain associated with Conflict Minerals is complex and we have been working with our suppliers to determine the sources of the Conflict Minerals in the raw materials supplied to us. As a result, ACTIA expects the following from its direct material suppliers:

  • To source minerals from non-conflict regions or, if sourced from conflict regions to identify whether the sourcing is conflict-free (i.e. not used to fund conflicts in Covered Countries) through a reasonable due diligence program.
  • To disclose to ACTIA via the Responsible Minerals Initiative reporting survey template (Conflict Minerals Reporting Template) the requested information necessary for ACTIA to accurately report as required.
  • To pass these requirements down to lower levels in their supply chain using reasonable efforts to determine the source of the specified minerals, if they do not source directly from smelters.

ACTIA collects conflict minerals due diligence information from its suppliers and requires the suppliers to provide smelter names, country of origin, contact information etc. We review due diligence information received from suppliers. Corrective action and follow-up are implemented with suppliers who provide inadequate or incomplete responses.

ACTIA’s Conflict Mineral Policy and subsequent updates will be communicated to our supply chain partners and stakeholders via our website. Compliance with this Policy will be a requirement for all direct material supplier contracts.

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