RSR North America Conflict Minerals Policy Statement
The U.S. Securities and Exchange Commission adopted rules pursuant to §1502 of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act that establish certain disclosure obligations for US public companies to the extent to which the products they manufacture or contract to manufacture contain certain “Conflict Minerals” including Tantalum, Tin, Tungsten and Gold, sourced from mines in the Democratic Republic of the Congo (DRC) or adjoining countries.
While the RSR North America (“RSR”) is not a US public company subject to the SEC* Conflict Minerals disclosure rules, RSR and its subsidiaries** take seriously their corporate responsibility to ensure materials used in their products are sourced in an ethical manner. In line with its corporate culture and ethics, RSR is committed to being a good corporate citizen including ensuring the health, safety and protection of people who come into contact with its products and business, as well as managing its obligations in relation to Conflict Minerals. RSR expects a similar commitment from its global supply chain partners.
After appropriate due diligence, RSR has determined that it currently requires the use of one or more of these listed minerals for the production of some of its products. However, RSR endeavors not to directly purchase any Conflict Minerals that directly or indirectly finance or benefit armed groups in the DRC or adjoining countries.
To this end, RSR requires its direct suppliers to be DRC conflict-free and in addition has implemented internal due diligence measures for conflict-free sourcing including, among other things, the collection of Conflict Minerals due diligence information such as Certificates of Origin, conflict-free minerals supplier declarations or Conflict Minerals policy statement; and maintaining Conflict Minerals sourcing compliance in the RSR North America Purchasing Policy.
Finally, should there be any suspicions that any Conflict Minerals supplier may have sourced or transshipped a supply originating from any of the covered countries, appropriate follow up measures will be taken with the supplier to ensure that such Conflict Minerals did not originate from Conflict Mines.
* RSR North America is not an SEC Registrant and accordingly does not file reports with the SEC.
** Quemetco Metals Ltd, Inc., Quemetco West, LLC, Eco-Bat Indiana, LLC, Eco-Bat New York, LLC.