Conflict Minerals Policy Statement
In response to the violence and human rights violations occurring when extracting some minerals from the “Conflict Region”, located in the eastern part of the Democratic Republic of Congo (DRC) and in neighbouring countries, KF undertakes to sustain the humanitarian objective to put a stop to the violent conflict in those areas.
The U.S. Securities and Exchange Commission (SEC) has prepared regulations concerning the detection and publication requirements related to “Conflict Minerals”, as indicated by the “Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502” of 2010.
The European Union issued a specific European Parliament and Council Regulation (EU) 2017/821 dated 17 May 2017 which “establishes diligence duty obligations in the procurement chain for those importing tin, tantalum and tungsten, their minerals and gold coming from conflict or high risk areas into the Union”,
The definition “conflict minerals” specifically refers to gold, tin, tantalum and tungsten, commonly called 3TG.
The commitment taken by KF develops as follows:
– to design and develop products that do not contain “conflict minerals”
– not to intentionally procure material containing the metals specified coming from mines and foundries in the “Conflict Region”, that are not certified as “Conflict Free”
– to ensure compliance with those requirements and ask its suppliers to undertake a suitable assessment process with their procurement chains, to ensure that the metals specified come:
– or solely from mines and foundries outside the “Conflict Region”
– or mines and foundries certified by an independent third party body as being “Conflict Free”, if located in the “Conflict Region”.
KF has implemented an internal procedure compliant with the relative sections of the guidelines recognised internationally by the OECD (Organisation of Economic Co-operation and Development).
KF requires its suppliers to perform suitable controls of their procurement chains in order to determine the place of origin of the 3TG minerals and whether the foundry or refinery has been certified as “conflict free” by an independent third party, or by using the Conflict Minerals Reporting Template questionnaire (drawn up by “cfsi”).
The goal is to guarantee that “Conflict Free” material and components are the only ones used in the products and processes purchased.
If the presence of minerals extracted or processed in structures NOT considered “Conflict Free” should be detected in any material, part or component purchased by KF, suitable actions will be taken to make the product sold “Conflict Free”.
