CONFLICT MINERALS

Conflict Minerals Policy

In response to the international community’s call for responsible mineral sourcing, S&S Tech regulates the use of conflict minerals and actively works to manage them together with its domestic and overseas suppliers.

1What is Conflict Minerals regulation?

As part of economic sanctions to eradicate social problems such as human-rights abuses, child-labor exploitation, and sexual violence in African conflict zones (10 countries including DR Congo), developed nations designate the four minerals (3TG: tin, tungsten, tantalum, gold) mined in these regions as conflict minerals. The regulation restricts companies’ use of conflict minerals to prevent mining proceeds from funding armed groups.

[ Conflict Minerals ]Minerals mined in conflict zones near the Congo in Central Africa (tin, tungsten, tantalum, gold)

Map of conflict-zone mineral distribution — Conflict zones (10 countries): DR Congo, Congo, Sudan, Rwanda, Uganda, Zambia, Angola, Tanzania, Central Africa, Burundi

Conflict-mineral reserves and industry-share statistics — In 2010, the U.S. Congress enacted the Dodd-Frank financial reform act mandating conflict-minerals reporting; U.S.-listed companies must report their conflict-minerals usage to the SEC every year.

2Conflict Minerals Response Policy

S&S TECH will comply with relevant regulations on internationally contested conflict minerals and, together with domestic and overseas suppliers, make active efforts to regulate and manage conflict minerals.
Using the conflict-minerals reporting questionnaire (EICC Template) provided by EICC-GeSi, we will thoroughly investigate the use of conflict minerals by surveying usage among domestic and overseas suppliers.
We will confirm and request in writing that domestic and overseas suppliers submit the conflict-minerals reporting questionnaire and a written statement of compliance that they do not use conflict minerals.
We will make it mandatory to identify the origin and smelter of suppliers’ conflict minerals and the origin of minerals used by those smelters, and will work together to comply with conflict-minerals regulations.
We will require identification of the origin and smelter of minerals used by domestic and overseas suppliers and the origin of the minerals those smelters use, ensuring compliance with conflict-minerals regulations, and will encourage adoption of minerals that comply with the CFS (Conflict-Free Smelter) program.
We will also add cobalt — an emerging human-rights issue due to child labor and other concerns — to conflict minerals and respond to it in the same manner.