Vulcan GMS uses wolframite (tungsten) and cassiterite (tin) in the manufacture of a number the company’s products.
These materials fall under the SEC’s conflict-minerals rule, a new regulation scheduled to go into effect in January, 2012. This regulation requires reporting on the sources of certain raw materials. The regulation seeks to interdict the flow of “conflict minerals,” which are defined as certain materials mined in situations of armed conflict and/or human rights abuses. Countries that currently fall within that definition include the Democratic Republic of the Congo and Rwanda.
The rule mandates that all publicly traded companies provide assurances that their sources of raw material do not violate the conflict-minerals rule. This rule includes assurances from the supply chains that provide materials, parts and assemblies to publicly traded companies.
Vulcan GMS has made substantial inquiries into its supply chain to document the origin of the materials the company purchases for use in its manufacturing processes. Upon completion of these inquiries, Vulcan GMS has determined that the vast majority of its tungsten comes from the DRC (Democratic Republic of China). The company has completed the process of obtaining verbal confirmation that it is in compliance with the SEC rule regarding wolframite (tungsten).
The company is also in the process of obtaining formal disclosure statements from all raw material suppliers to substantially and thoroughly document every source of supply for tungsten.
Further, the company has completed similar inquiries regarding its sources of cassiterite (tin). As with wolframite, Vulcan GMS is obtaining formal disclosure statements from tin suppliers, where applicable, that will document the country of origin for all tin materials. These documents will provide assurances that no material purchased by or used in the company’s manufacturing processes is sourced from conflict-minerals areas such as the Democratic Republic of the Congo or Rwanda.
Vulcan GMS expects to have its supply chain inquiries and disclosure documents completed by the time the new rule goes into effect.
For more information on the Vulcan GMS initiative to comply with the SEC conflict-minerals rule, contact Tom Trisco at: ttrisco@vulcangms.com
Posted: December 15, 2011