Responsible Sourcing of Conflict Minerals
Many of our products, like virtually all consumer electronics, contain various metals, including tantalum, tin, tungsten and gold (commonly referred to as “3TG”), which originate in mines around the world. The 3TG metals have become known as “conflict minerals” because much of it is sourced from the Democratic Republic of the Congo (“DRC”) and adjoining countries (together, with the DRC, the “Covered Countries”) where a decades-long civil war is being waged. This conflict has been exacerbated by various groups fighting to control mines and transit routes used in the trade of these minerals.
In the U.S., the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requires public companies to file annual reports with the U.S. Securities and Exchange Commission beginning in May 2014, disclosing whether or not they are using 3TG originating from the Covered Countries. A potential, but unintended, consequence of the Dodd-Frank Act is a widespread withdrawal from trade with the Covered Countries by U.S. companies.
We believe it is essential to establish validated, conflict-free sources of 3TG within the Covered Countries so that these minerals can be procured in a way that contributes to economic growth and development in the regions. We believe a widespread withdrawal from trade with the Covered Countries by US companies should be avoided. We aim to partner with governmental organizations, industry groups and non-governmental organizations to achieve a workable solution.
We expect our suppliers to source only from certified conflict-free smelters, such as those audited by the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program. If we determine that our expectation is not met, we will work with the supplier and the industry to enable conflict-free sourcing. For example, Google advises its suppliers to take similar measures with their own sub‐suppliers to ensure alignment and traceability throughout the supply chain and back to the smelter. Furthermore, under the Google Supplier Code of Conduct, Google expects its suppliers to perform due diligence on the source and chain of custody of minerals used in the manufacturing of products they supply to Google. Suppliers’ due diligence measures should be available to us upon request.