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Policy on Preventing the Use of Conflict Minerals

This web page sets forth the policy of Mosaic Industries, Inc. regarding preventing the use of Conflict Minerals.

In recent years, armed factions in the Democratic Republic of the Congo (DRC) and nearby countries have been illegally mining and smuggling minerals to fund themselves and their wars. These groups further armed conflict and violate human rights through slavery, forced labor and abusive treatment of local people. The conflict minerals they mine are smelted into metals that find their way into many industrial and consumer electronic products.

These conflict minerals include:

Countries Sourcing Conflict Minerals
Central African Republic
Angola     Rwanda     Uganda
South Sudan     Republic of Congo
Zambia    Burundi    Tanzania    Malawi
Democratic Republic of the Congo
Cassiterite, an ore containing tin, which is widely used to plate integrated circuit leads, wires, and PCBs. Tin is also the primary constituent of solder.

Columbite-tantalite (aka Coltan), containing niobium and tantalum metals, used in the construction of capacitors and for metal interconnects in wafer fabrication.

Gold, which is widely used for corrosion resistant wires, connector contacts, and wire-bonds within ICs.

Wolframite, which is smelted to tungsten metal and used for corrosion resistant or high temperature interconnects, light bulb filaments, welding, and for weights used in vibrating motors.

At Mosaic Industries, Inc. we do not directly purchase these minerals or the metals smelted from them. Even so, every component on our computer boards, every connector, the boards themselves, and the solder used in their assembly are all likely to include one or more metals refined from minerals that could potentially have been mined in a conflict zone.

Industries Affected
  • Aerospace
  • Consumer Electronics
  • Industrial Equipment
  • Automotive
  • Medical Equipment
  • Industrial Manufacturing
  • Semiconductor
  • Construction
  • Research and Development

Just like consumers buying electronic products, as a downstream user of electronic components we are not positioned to be able to ascertain for ourselves the ultimate source of metals used in the products we purchase. But we are disturbed by the atrocities being committed in the Democratic Republic of the Congo (DRC) and other conflict zones, and we want to do everything we can to assure that these horrible acts are not ultimately financed by our purchases through the electronics supply chain. We will never knowingly use metals or products containing metals sourced from conflict regions.

Consequently, we are using our reasonable best efforts to ensure that we do not use components that may contain metals refined from conflict minerals. To help address this problem, Section 1502 of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act incorporates a provision that requires that publicly-traded US manufacturers annually report their use of conflict minerals. The provision seeks to deter – through increased transparency of companies’ sourcing practices – the extreme violence and human rights violations in conflict regions. Although Mosaic Industries is not subject to the conflict metals reporting requirements of the Dodd-Frank Act, we understand that many of our customers are. We therefore intend to work with our suppliers and customers to assure that conflict minerals are not used in our supply chain.

To this end, we are following the best guidance available for assuring that we do not use components that may contain conflict minerals, including:

Because we don't purchase these metals directly, either from smelters or mines, we must rely on the source information provided by our suppliers and their reports on their use of the metals.

If Mosaic Industries becomes aware of a vendor whose products include metals from a conflict region, we will take appropriate actions, including reassessment of our supplier relationships. We expect our suppliers to pass up similar requirements to their suppliers to ensure compliance through the entire supply chain.

At Mosaic Industries we believe we have an imperative to be a socially responsible company in our global community. We are committed to continually evaluating our business practices in view of the moral principles important to us, while considering the interests not only of our customers and suppliers but also of our employees and the communities where we live and work. In this matter like all others, we are committed to sound ethical practices and compliance with all applicable regulations and laws, as they continue to evolve.

Expectations for our Suppliers
Mosaic Industries' suppliers are expected to assure that parts and components supplied to Mosaic Industries are conflict-free, without metals derived from conflict minerals. To assure responsible supply chain management, suppliers must establish policies, due diligence procedures and management systems consistent with industry best practice. We require of each supplier that they provide us with a Conflict Minerals Report based on the standardized reporting template available from the Conflict-Free Sourcing Initiative (CFSI).
Customers may request our Conflict Minerals Report
Mosaic Industries' customers may request our declaration of compliance with industry best practices for the elimination of conflict minerals from the supply chain. We use a Conflict Minerals Report based on the standardized reporting template from the Conflict-Free Sourcing Initiative (CFSI). Contact us to request a copy of Mosaic's Conflict Minerals Report or our Conflict Minerals Due Diligence Report which describes in more detail our procedures for identifying smelters used by our suppliers.

For more information on conflict minerals, efforts being made to assure they are removed from the electronics supply chain, and guidelines on implementing Dodd-Frank, please consult these useful resources:

Practical Guidance The Conflict-Free Sourcing Initiative's Reasonable Practices to Identify Sources of Conflict Minerals: Practical Guidance for Downstream Companies.

Conflict Minerals Guidelines of the Electronic Components Industry Association.

Conflict Minerals Due Diligence Guidelines, an evolving IPC standard.

Conflict-Free Sourcing Initiative Reporting Template.

Summary of Dodd-Frank Section 1502: Conflict minerals

Frequently Asked Questions about complying with the Dodd-Frank Conflict Minerals requirements.

The Conflict-Free Sourcing Initiative is a resource for companies contending with conflict minerals issues.

The Conflict-Free Smelter Program of the Conflict-Free Sourcing Initiative provides an audit tool to help determine which smelters and refiners can be validated as “conflict-free”.

Conflict Minerals Supplier Training by Flextronic.

The Solutions for Hope Project is an industry partnership striving to create a closed-pipe supply system for coltan from the Democratic Republic of Congo (DRC).

Global Witness's summary of the impact of the conflict minerals provision of the Dodd-Frank Act.

Section 1502 of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act

What’s Wrong with Dodd-Frank 1502? explores conflict minerals, civilian livelihoods, and the unintended consequences of Western advocacy.

This page is about: Policy on Preventing Use of Conflict Minerals – This web page sets forth policy of Mosaic Industries, Inc. regarding preventing use of Conflict Minerals. In recent years, armed factions in Democratic Republic of Congo (DRC) and nearby countries have been illegally mining and smuggling minerals to fund …