Atkore Prepares for Conflict Minerals Reporting
The May 31, 2014 deadline for SEC reporting companies to disclose the presence of conflict minerals in the products they manufacture is fast-approaching. For the past year, Atkore has been working closely with its suppliers around the world to ensure that all materials used in the manufacture of its products are free of conflict minerals.
On August 22, 2012, the Securities and Exchange Commission (SEC) approved a final rule requiring reporting companies to disclose their use of tantalum, tin, tungsten and gold originating from the Democratic Republic of the Congo (“DRC”) or adjoining countries in the products they manufacture or contract for manufacture. This conflict minerals rule was implemented to address concerns that revenues from the sales of certain minerals mined in the DRC and surrounding countries were being used to fund armed groups responsible for extreme violence in the DRC region.
To comply with the conflict mineral disclosure requirement, SEC reporting companies must conduct a reasonable country of origin inquiry (RCOI) to determine if conflict minerals from mines located in the DRC or adjoining countries are used in the manufacture of their products. To adhere to this new regulatory requirement, Atkore formed a Conflict Minerals Steering Committee to develop a comprehensive RCOI process. This process commenced with a thorough review of the materials used in all Atkore products by a cross-functional Atkore team. Based on this review, questionnaires were sent to Atkore suppliers directing them to identify any conflict minerals contained in the materials they supply to Atkore, and to verify the country origin of such minerals. This was a tremendous global undertaking and Atkore appreciates the timely cooperation provided by its suppliers.
While we are still in the process of finalizing our RCOI review in anticipation of the May 31st reporting deadline, Atkore can report that to date, we have received no information indicating that any supplier materials used in the manufacture of our products contain conflict minerals from the DRC or adjoining countries.
If you have any conflict mineral questions concerning the specific products that we supply to your company, please contact Ray Horner at firstname.lastname@example.org.