Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires publicly traded companies to report their use of “Conflict Minerals” (tin, tantalum, tungsten and gold) to the U.S. Securities and Exchange Commission. While New England Tubing is not required to report to the SEC, we are actively conducting reasonable country of origin inquiries with our raw material suppliers to support our customers.
The majority of our suppliers have stated their supply chains are “Conflict Free”; either their products do not contain the aforementioned metals or these metals do not originate from areas of conflict. Many suppliers are still determining smelter and mine of origin. A small number are still performing their supply chain investigation and have not provided a conclusive response. We will do our best to ensure we have significant statements from these suppliers. New England Tubing uses the EICC GeSI Conflict Mineral Reporting Template as its primary method of performing supply chain investigation and reasonable country of origin inquiries.
Upon request, New England Tubing can provide statements on the presence and origin of “Conflict Minerals” in the supply chain of specific finished good part numbers.
Conflict Free Supply Chain Requirements
While New England Tubing cannot guarantee its entire supply chain is conflict free until all of its suppliers complete their investigations, we can ensure specified finished goods are conflict free.
Response to company level questions found on the EICC GeSI Conflict Minerals Reporting Template
- Do you have a policy in place that addresses conflict mineral sourcing? Yes.
- Is this policy publicly available on your website? Yes. See above.
- Do you require your direct suppliers to be DRC conflict-free? No.
- Do you require your direct suppliers to source from smelters validated by an independent, private sector audit firm? No.
- Have you implemented due diligence measures for conflict-free sourcing? Yes. New England Tubing requests smelter and mine of origin information from suppliers who state their minerals or supply chain are conflict free.
- Do you collect conflict minerals due diligence information from your suppliers which is in conformance with IPC-1755 Conflict Minerals Data Exchange Standard (EICC/CMRT forms)? Yes.
- Do you request smelter names from your suppliers? Yes.
- Do you verify due diligence information received from your suppliers against your company’s expectations? Yes. New England Tubing reviews customer forms for accuracy and completeness.
- Does your verification process include corrective action management? Yes. New England Tubing requests additional information from suppliers if any EICC sections are incomplete.
- Are you subject to the SEC Conflict Minerals Disclosure requirements? No.