The extraction of certain raw materials in the Democratic Republic of Congo (DRC) and the neighboring countries contributes in some measure to significant violations of human rights and the financing of violent conflicts in this region. The Congress of the United States of America passed the “Dodd-Frank Wall Street Reform and Consumer Protection Act” (Dodd-Frank Act) in 2010. Section 1502 of the Dodd-Frank Act and the implementation rules of the U.S. Securities and Exchange Commission (SEC) require from companies subject to SEC supervision a report indicating whether the products that are produced by them or whose production they have commissioned contain “conflict materials” that are “necessary for the functionality or production” of these products.
The Dodd-Frank Act and the SEC define “conflict minerals” as tantalum, tin, tungsten (and the ores from which they are obtained), and gold, regardless of where they are obtained, processed, or sold. KLINGELNBERG GmbH (including all associated companies) is not subject to SEC supervision and therefore has no legal obligation to fulfill the requirements pertaining to conflict minerals as stipulated in section 1502 of the Dodd-Frank Act. At the same time, we recognize that the SEC provisions of section 1502 require our direct and indirect customers to perform due diligence within their global supply chains. We will assist them appropriately in fulfilling their reporting obligations.
Statement: KLINGELNBERG GmbH endeavors not to purchase material containing “conflict materials” that directly or indirectly finance or benefit armed groups in the DRC or the neighboring states. We implement appropriate processes to understand where in our products “conflict minerals” are contained, as well as to determine the source and origin in our supply chain. These activities are based on the established frameworks of the Organisation for Economic Co-operation and Development (OECD) and other industry initiatives. Due to the variety of the products we offer and the high complexity of the corresponding supply chains, this is a challenging and ongoing process. We will contact our direct suppliers to increase transparency with respect to the products supplied by them. We will continue to work closely with customers, suppliers, and other stakeholders concerning constructive efforts and practical solutions.