Circular of 11.02.2014
DODD-FRANK ACT
Under the US Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”), Section 1502, certain companies are specifically required to report to their respective Securities and Exchange Commissions. In addition, companies are required to report annually on whether their products contain conflict minerals (currently focused on: columbite-tantalite, coltan, cassiterite, gold, wolframite or their derivatives) from the Democratic Republic of Congo or contiguous countries specified by the Dodd-Frank Act. As a result, the companies of the BÖHLER Specialty Steel Division can affirm that we comply with the Dodd-Frank Act and that none of the minerals we use come from conflict zones.
In order to ensure compliance with the Dodd-Frank Act in the Specialty Steel Division, Voestalpine’s management team has decided that the companies in this division will only purchase raw materials and other products containing minerals from conflict zones from suppliers that provide a full report from the Electronic Industry Citizenship Coalition, Incorporated (http://www.eicc.info) assuring that the minerals present in the purchased raw materials or products do not originate from the Democratic Republic of Congo or contiguous countries, and that the required measures have been taken to ensure this.
This resolution is mandatory and binding for all companies of the BÖHLER Special Steels Division. The Special Steels Division includes all companies in which Voestalpine has a direct or indirect interest of at least 50% or which are under its control.
In the case of BÖHLER-UDDEHOLM IBÉRICA S.A.U., the conditions are fully met, so that the companies of the BÖHLER Specialty Steel Division use the following statements to assure our customers that their supplies comply with the Dodd-Frank Act:
A. ORIGEN
: Having received the commitment of all our suppliers of raw materials, we certify that the Tungsten (W) [usado en nuestra producción /contenido de nuestros productos] does not come from the Democratic Republic of Congo nor from contiguous countries.
B. OUR PRODUCTS DO NOT CONTAIN CONFLICT MINERALS
At the request of our customers, we have reviewed the historical sales of all BÖHLER grades and none of the grades supplied in the last 12 months have been alloyed with conflict minerals, nor have they been used in our production processes or in materials supplied from our suppliers.
If in doubt, please contact us for further information.
