“Conflict Minerals" refers to minerals such as tin, tantalum, tungsten, and gold (3TG) produced in disputing countries, including the Democratic Republic of the Congo or its neighboring nations.
Funds generated by conflict minerals flow into militants in the country, leading to the massacre of their own citizens, and the violation of human rights, including issues such as child labor, forced labor, and violence against women that may occur during the mining process.
Amid growing international concerns, the U.S. Congress enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act in 2010, which mandated reporting on the use of conflict minerals. Pursuant to Section 1502 of the aforementioned legislation, companies listed on U.S. stock markets are required to investigate and report on the use and origin of conflict minerals, conduct supply chain due diligence, and submit the findings to the U.S. Securities and Exchange Commission.
HFR will act as a responsible corporate citizen to ensure that conflict minerals associated with armed groups in conflict zones are not included in its supply chain for product manufacturing. To achieve this, HFR will implement the following procedures:
1) HFR will establish a conflict minerals business process for legal compliance by applying international standards regulating conflict minerals. Additionally, we will actively support initiatives by the Responsible Minerals Initiative (RMI) aimed at prohibiting the use of conflict minerals.
2) HFR will utilize the Conflict Minerals Reporting Template (CMRT) provided by the Responsible Minerals Initiative (RMI) to identify all smelters' names and locations involved in the refining of tin, tantalum, tungsten, and gold used in our products.
3) HFR will request our business partners to submit the Conflict Minerals Reporting Template (CMRT) and provide written confirmation that they do not use conflict minerals.
4) HFR will support our business partners in purchasing conflict-free minerals from smelters certified through the Responsible Minerals Assurance Process (RMAP).
5) HFR will establish audit procedures in accordance with the OECD Due Diligence Guidance, and if necessary, conduct audits of the procedures and documentation undertaken by our business
HFR demands that all our business partners thoroughly understand the conflict minerals-related laws in the United States and adhere strictly to our conflict minerals management policy to ensure consistent application throughout the entire supply chain.
For this purpose, HFR's business partners must perform the following procedures.
1) Business partners must establish documented conflict minerals management policies and procedures to ensure that the products delivered to HFR do not contain conflict minerals benefiting armed groups in the Democratic Republic of the Congo or its neighboring nations.
2) Business partners should make diligent efforts to identify the names and locations of all smelters where conflict minerals within the supply chain are purchased.
3) In response to HFR's request, business partners must prepare and submit the Conflict Minerals Reporting Template in a timely manner.
4) Business partners must promptly take corrective actions if risks are identified within the supply chain.
If HFR does not receive sufficient information from the business partner to confirm the use of conflict minerals, or if the business partner provides inaccurate information, and if risks are identified within the business partner's supply chain but corrective actions are not taken, HFR may consider discontinuing transactions with the respective business partner.
HFR will actively collaborate with its business partners and customers in international efforts to prohibit the use of conflict minerals, thereby fulfilling its social responsibility to protect human rights in the Democratic Republic of the Congo and neighboring nations.