A.M. Castle & Co. is committed to supporting responsible sourcing of minerals throughout our global supply chain. In August 2012, the U.S. Securities and Exchange Commission (the "SEC") issued final rules implementing the provisions of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). As a result, we are required to submit annual disclosures regarding whether certain minerals, consisting of gold or columbite-tantalite (coltan), cassiterite, wolframite, or their derivatives, which are initially limited to tin, tungsten and tantalum (collectively, "3TG") used to manufacture our products, originated in the Democratic Republic of Congo ("DRC") or its adjoining countries (together with the DRC, the "Covered Countries").
Castle supports the intent of the Dodd-Frank Act to prevent armed groups in the Covered Countries from benefiting from the sourcing of 3TG in that region. To that end, Castle has conducted a reasonable country of origin inquiry, informed by the Organisation for Economic Co-operation and Development’s Due Diligence Guidance, to identify the source of the 3TG that are necessary to the functionality or production of our products. Suppliers who were unable to certify that their materials are DRC conflict free have been removed from our approved supplier list.
We continue to emphasize the importance of business practices that support responsible sourcing of conflict free minerals through implementation of ongoing compliance actions where appropriate in our various operations, including the following:
- Development of supplier qualification and re-qualification processes that include mandatory conflict free documentation requirements;
- Implementation of affirmative supplier certifications regarding the sources of all materials currently being supplied to Castle, as well as all future materials;
- Amendment of our standard purchase terms & conditions to require all materials supplied must be DRC conflict free; and
- Issuance and annual review of our formal Conflict Minerals Statement and the underlying compliance processes supporting the same.