WHAT IS THIS POLICY?
Sophos Group Limited and Sophos Holdings, LLC and their respective subsidiaries (collectively, the “Company” or “Sophos”) is committed to social, ethical, and environmental responsibility in its activities, as well as within our supply chain, in this Conflict Minerals Policy (the “Policy”). In addition to our commitment, we must meet the legal and regulatory requirements of the laws governing conflict minerals, in addition to specific customer requirements. Further, Sophos adheres to the Code of Conduct of the Responsible Business Alliance, specifically Section D.7., Responsible Sourcing of Minerals, in its administration of this Policy. In this regard, we have an opportunity and an obligation to promote human rights whereby making a positive contribution and by operating in compliance with all applicable laws wherever we do business.
WHY MUST WE HAVE THIS POLICY?
In 2012, the U.S. Securities and Exchange Commission released regulations governing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”), which aim to prevent the use of certain minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo and adjoining countries . Specifically, the Act requires U.S. publicly traded companies to trace the Tantalum, Tin, Tungsten and Gold in their products through the supply chain and disclose whether they came from “conflict mines” in the Democratic Republic of the Congo (DRC).
Similarly, in November 2016 the European Union acted to ensure sustainable sourcing of EU imports of tin, tantalum, tungsten and gold (the “Directive”). This regulation will become effective 01 January 2021. The regulation aims to:
- Ensure that EU importers of 3TG (tin, tungsten, tantalum and gold) meet international responsible sourcing standards, set by the Organization for Economic Co-operation and Development (OECD)
- Ensure that global and EU smelters and refiners of 3TG source responsibly
- Help break the link between conflict and the illegal exploitation of minerals
- Help put an end to the exploitation and abuse of local communities, including mine workers, and support local development
In both instances, “Conflict Minerals” are known specifically as tin, tungsten, tantalum, and gold; are commonly referred to as 3TG; and generally includes any other mineral determined to be financing conflict in the Democratic Republic of the Congo or an adjoining country.
HOW DOES SOPHOS COMPLY WITH THESE REGULATORY REQUIREMENTS?
Sophos supports the objective of the Act and forthcoming Directive, and requires transparency in its supply chain to identify the sources of conflict minerals as accurately as possible to avoid the use of such conflict minerals that directly or indirectly finance such conflict. Sophos is not a direct importer of Conflict Minerals. However, it is Sophos policy and expectation that its suppliers have active policies and procedures that reasonably identify, remove, and reject the use of conflict minerals in their purchases.
The Electronics Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) have created a Conflict Minerals Reporting Template as a common means to collect information to validate the source of Tantalum, Tin, Tungsten and Gold. This template and training materials can be found at www.conflictfreesmelter.org.
WHAT ARE THE SPECIFIC SOPHOS COMPANY ACTIONS TO COMPLY?
Sophos uses the template to perform internal due diligence and to meet reporting requirements. For example, we require the following from our suppliers to determine whether conflict minerals are added and are necessary to the functionality or production of any applicable product:
- A completed EICC-GeSI Conflict Minerals Reporting template.
- Provide a certification that the products supplied to Sophos, that contain tantalum, tin, tungsten or gold, did not originate from the Democratic Republic of the Congo or adjoining countries.
- Provide the names and pertinent information of the smelters they use.
Sophos will take these and other appropriate actions to comply with conflict mineral statutes and regulation in addition to supporting our customers to reach our common goal to build up a socially and environmentally responsible supply chain.
For further information email the Compliance Team: Compliance@sophos.com.