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ELGILOY SPECIALTY METALS
DIVISION OF COMBINED METALS OF CHICAGO LLC
1565 Fleetwood Drive
Elgin, IL 60123
Telephone: 847-695-1900
Fax: 847-899-0183
04/08/2019
Conflict Minerals Policy
Elgiloy Specialty Metals is committed to being a responsible corporate citizen and is
opposed to human rights abuses. As part of that commitment, Elgiloy seeks to
source products, components and materials from companies that share our values
around human rights, ethics, and environmental responsibility.
In August 2012, the U.S. Securities and Exchange Commission (“SEC”) adopted
final rules implementing Section 1502 of the Dodd-Frank Wall Street Reform and
Consumer Protection Act (the “Conflict Minerals Rule”). Under these rules, publicly
traded companies must annually report to the SEC whether the products they
manufacture or contract to manufacture contain “conflict minerals” originating from
the Democratic Republic of the Congo (the “DRC”) or adjoining countries. Revenue
from the mining and transport of these conflict minerals is believed to be financing or
benefiting groups that are responsible for human rights violations. The four most
commonly mined conflict minerals (known as 3TGs, from their initials) refers to the
metals of tantalum, tin, tungsten and gold, which are the derivatives of the minerals
cassiterite, columbite-tantalite and wolframite, respectively.
Elgiloy supports industry-wide efforts to identify, reduce and hopefully eliminate the
use of conflict minerals originating from the DRC and adjoining countries to the extent
believed to be financing or benefiting groups committing human rights violations.
Elgiloy is committed to complying with any applicable requirements under the
Conflict Minerals Rule and has implemented a due-diligence process to meet its
obligations under the legislation.
Suppliers to Elgiloy are expected to establish their own conflict minerals policies, due
diligence frameworks and management systems that are designed to prevent conflict
minerals originating from the DRC or an adjoining country, to the extent that they
benefit groups committing human rights violations, from being included in the products
sold to Elgiloy. In the event Elgiloy determines that a supplier has failed to develop
and implement reasonable steps to comply with this Policy, Elgiloy reserves the right
to take appropriate actions, which may include discontinuing the business relation ship
with the supplier.