Conflict Minerals

The U.S. Securities and Exchange Commission (SEC) on August 22, 2012 adopted conflict minerals regulations (the “Rule”) in support of Section 1502 the Dodd-Frank Wall Street Reform and Consumer Protection Act, including 13(p) of the Securities Exchange Act of 1934.

The Rule requires public companies to disclose the use of conflict minerals contained in their products. Specifically, the Rule is meant to identify and reduce the utilization of conflict mineral sourcing operations in the Democratic Republic of Congo (DRC) region that did fund or may reasonably be believed to have funded armed conflict in the DRC and adjoining countries. Through the public disclosure requirement, industry will bring greater public awareness of the source of conflict minerals and whether their sourcing may have contributed to human rights abuses.

What are Conflict Minerals?

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“Conflict Minerals” is the term used to describe the following minerals: gold, wolframite, casserite, columbite-tantalite and their derivative metals, which include tin, tungsten and tantalum – no matter where they are mined or smelted. Conflict Minerals are also referred to as “3TGs.”

HII Policy

HII is committed to sourcing components and materials from suppliers that share its ethical values and that support compliance with the SEC regulations on conflict minerals. HII will refrain from obtaining conflict minerals from sources that could result in aiding, directly or indirectly, armed groups operating in the DRC or its adjoining countries when it does not conflict with contractual obligations with the U.S. Government. HII does support the sourcing of conflict minerals from the DRC or its adjoining countries through smelters that have been certified as “conflict-free.”