On July 21st 2010, President Obama signed into law the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act ("Act"), which seeks to prevent armed groups from financing conflicts in the Democratic Republic of Congo (“DRC”) through the sale of certain minerals extracted from that region.
In August of 2012, the Security and Exchange Commission (“SEC”) published final rules implementing the Act. The SEC requires that certain publicly traded companies disclose their use of “conflict minerals” (defined by the Act as “columbite-tantalite, cassiterite, gold, wolframite, and their derivatives and further defined by the SEC to include tin, tungsten, tantalum and gold) sourced from the DRC or adjoining countries. The SEC has ruled that disclosure is required when a final product contains a “conflict mineral” that is “necessary to the functionality or production of the product”, even when the “conflict mineral” appears in the final product in a de minimis amount.
Arkema is not required to make disclosures under the Act, and Arkema does not directly purchase “conflict minerals” as identified by the SEC. Arkema is however committed to responsible sourcing and to assisting our customers in their compliance with the Act. Arkema is responding to customer inquiries as to whether the products purchased contain "conflict minerals" as defined by the SEC.
To the extent Arkema purchases products from our suppliers that contain "conflict minerals" as defined by the SEC, Arkema is requiring that our suppliers inform us regarding the origin of such minerals.
As a matter of responsible sourcing, Arkema will use best efforts not to acquire any raw materials that Arkema has reason to believe originate from the DRC or adjoining countries unless such materials are certified as "conflict free”.