• | Adopted a Conflict Minerals Compliance Policy governing the supply chain of Conflict Minerals from the Conflict Areas. |
• | Communicated DMC's Conflicts Mineral Compliance Policy to our employees and suppliers. |
• | Created an internal Conflict Minerals Compliance Team to design and lead DMC's due diligence and risk mitigation efforts. |
• | Identified all suppliers from which DMC purchased raw materials during 2013. |
• | Requested that each such supplier provide DMC information about the extent to which its products purchased by DMC did or did not include any Conflict Minerals. |
• | Obtained (as the preferred reporting format from each supplier) a completed Conflict Minerals Reporting Template, which was developed by the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative ("EICC/GeSI") |
• | Identified any supplier who in its response to DMC had indicated that its product(s) may have contained Conflict Minerals from the Conflict Areas. |
• | Identified the supplier who supplied products which may have contained Conflict Minerals to our supplier. |
• | Verified the above identified supplier was listed as compliant with the Conflict-Free Smelter Program assessment protocols of the Conflict Free Sourcing Initiative and thus did meet the requirements for classification as a Conflict-Free Smelter. |
• | Products: certain powders and pastes used in the Oilfield Products division. |
• | Facilities Used to Produce the Conflict Minerals/Efforts to Determine Mine or Location of Origin: DMC conducted due diligence (as described in more detail above) on one tin supplier and determined it was listed on the Conflict-Free Smelter list of the Conflict Free Sourcing Initiative. |
• | Country of Origin: Majority of tin smelter intake from the Covered Countries was from Rwanda and the Katanga Province of the Democratic Republic of the Congo. |
• | Increasing the response rate from suppliers; |
• | Including a conflict minerals assessment in the supplier approval process; and |
• | Reviewing—and enhancing where we deem appropriate—the composition and training of the internal DMC group leading DMC’s conflict minerals compliance efforts. |