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Conflict Minerals Policy


The United Nations Group of Experts on the Democratic Republic of Congo (DRC) found that the trade of certain minerals (Columbite-Tantalite (Coltan/Tantalum), Cassiterite (Tin), Wolframite (Tungsten) and Gold), called conflict Minerals (3TG), is helping to finance the civil conflict in the DRC characterized by extreme levels of violence, particularly sexual and gender-based violence.

In July 2010, US President Barack Obama signed the “Dodd-Frank Wall Street Reform and Consumer Protection Act” which includes section 1502(b) on Conflict Minerals.

US Securities and Exchange Commission (SEC) released final rules in August 2012 requiring all public companies to disclose and report annually to the Securities and Exchange Commission (SEC) if the minerals they use in their products (Tin, Tantalum, Tungsten and Gold, so-called 3TG), originated from the DRC and adjoining countries.

Our Policy

“Conflict Minerals” refers to minerals or other derivatives mined in the eastern provinces of the Democratic Republic of the Congo (DRC) and in the adjoining countries where revenues may be directly or indirectly financing armed groups engaged in civil war resulting in serious social and environmental abuses. In July 2010, the United States passed HR4173, the Dodd-Frank Financial Reform Bill section 1502(b), requiring all US stock-listed companies and their suppliers to disclose the chain of custody usage of conflict minerals (Tin, Tantalum, Tungsten and Gold). ZAPI GROUP fully supports this legislation, and the Electronic Industry Citizenship Coalition (EICC)/Global e-Sustainability Initiative (GeSI) position to assure that specified minerals are not being sourced from mines in the “Conflict Region”, which is controlled by non-government military groups. Furthermore, ZAPI GROUP intends to adopt the EICC Due Diligence reporting process. It will make all commercial best efforts to obtain chain of custody declarations from all ZAPI GROUP sourced and managed suppliers with the aim of ensuring transparency in our supply chain. ZAPI GROUP expects its suppliers to:

  • Source materials from socially responsible suppliers who have confirmed non-conflict sources, even if those sources do come from the DRC and surrounding area.
  • Comply with the Dodd-Frank regulation and provide all necessary declarations in the form of the EICC-GESI Conflict Minerals Reporting Template as adopted by EICC-GESI on a regular base or in any other form that the Buyer reasonably requests.
  • Pass this requirement onto their supply chain if they don’t source directly from smelters and determine the source of specified minerals.

Suppliers who are non-compliant with these requirements shall be reviewed by Global Supply Chain for future business.

The General Management