This policy applies to the minerals tantalum, tin, tungsten and gold (referred to as 3TG). Mining, trading, handling and exporting these minerals and related ores from conflict-affected and high-risk areas (CAHRAs) or covered countries (Democratic Republic of Congo and adjoining countries) can e.g. negatively impact human health, can relate to human rights abuses and can be used for financing armed conflicts.
The U.S. Dodd‐Frank Wall Street Reform and Customer Protection Act, Section 1502 and SEC regulations require disclosure of the use of 3TG and transparency within the supply chain in order to end armed conflicts and heed international law. The focus is put on the covered countries.
On January 1, 2021, the EU regulation on 3TGs (Regulation (EU) 2017/821) came into force. Directly affected EU importers of minerals and metals over certain thresholds have to comply with the respective supply chain due diligence obligations. The EU regulation refers to CAHRAs, which are updated regularly and can include regions worldwide.
In line with the above-mentioned requirements, FAULHABER is aware of its responsibility and is contributing at various levels to sustainably protect human rights. FAULHABER is committed to ensuring the health, safety and protection of the people who extract and mine 3TGs. It is our responsibility to demand high social, environmental and human rights standards from our suppliers, too. Even though FAULHABER is not directly affected by the Dodd‐Frank Act, Section 1502 nor by the EU Regulation 2017/821, and has no direct mining, smelting, or trading activities of such minerals in CAHRAs, neither in covered countries, Faulhaber is engaging in its supply chain in order to source required 3TGs responsibly.
FAULHABER acknowledges this policy and is committed to raise awareness for responsible sourcing of these minerals. FAULHABER is constantly working on further increasing transparency in the supply chain and ensuring responsible mining, smelting, or trading activities of the 3TG that we use in our products. We are thus committed to:
Information about the 3TGs used by FAULHABER is disclosed annually in the form of a Conflict Minerals Reporting Template (CMRT), which is prepared based on feedback from relevant suppliers and made available on the FAULHABER website.
FAULHABER has defined the following measures to fulfil our responsibility and ensure transparency in the supply chain: