Alphabet’s Conflict Minerals Policy

Responsible Sourcing of Conflict Minerals

Background

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.

Our Commitment

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.

Conflict Minerals Report

For more information on our due diligence efforts regarding the conflict minerals in our supply chain, please refer to our Conflict Minerals Reports.

Download Alphabet's 2016 Conflict Minerals Report
Download Alphabet's 2015 Conflict Minerals Report
Download Google's 2014 Conflict Minerals Report
Download Google's 2013 Conflict Minerals Report

Please refer here for a list of smelters provided by our suppliers and verified as smelters by the Conflict-Free Sourcing Initiative for our 2016 in-scope products.

Our Partnerships

We are partnering with governmental organizations, industry groups and non-governmental organizations to further conflict-free initiatives. For example:

  • Google has been a member of the Conflict-Free Sourcing Initiative since 2013 (member ID: GOOG) and has supported its flagship program, the Conflict-Free Smelter Program. In 2016, the membership was transferred from Google to Alphabet.
  • Google has contributed to the Initial Audit Fund, a program managed by the Conflict-Free Sourcing Initiative, which offers smelters an incentive for participating in the Conflict-Free Smelter Program by fully paying for the costs of their initial audit when they are determined to be compliant. Google’s contributions to the audit fund have enabled over 50 audits. Google is proud to support efforts like the CFSP that drive industry level compliance.
  • In 2014, Google joined other companies supporting the Solutions for Hope Gold initiative. “Solutions for Hope is a platform that supports companies, civil society organizations, and governments working together to responsibly source minerals from regions experiencing conflict where market access is limited by opaque supply chains.” - Solutions for Hope website
  • In 2015, Google joined the Public-Private Alliance for Responsible Minerals Trade. “The Public-Private Alliance for Responsible Minerals Trade (PPA) is a multi-sector and multi-stakeholder initiative to support supply chain solutions to conflict minerals challenges in the Democratic Republic of Congo (DRC) and the Great Lakes Region (GLR) of Central Africa. The PPA provides funding and coordination support to organizations working within the region to develop verifiable conflict-free supply chains; align due diligence programs and practices; encourage responsible sourcing from the region; promote transparency; and bolster in-region civil society and governmental capacity.” - PPA website
  • In 2016, Google contributed to Pact. With Google’s support, Pact will focus on two primary objectives: first, to address the needs of particularly vulnerable and older children remaining in the mines who require additional interventions in order to be able to voluntarily leave the mines; and second, to enhance the technical and institutional capacities of local systems relevant to child protection—spanning government, civil society, and mutual aid groups—so that advances made by the project can be sustained by local actors over the long term.

Back to top