On 22 August 2012, the U.S. Securities and Exchange Commission (SEC) published regulations implementing Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act governing Conflict Minerals. PMG Company complies with the SEC regulations requiring supply chain reporting and reasonable due diligence with respect to the sourcing of these minerals and the products in which they are contained.
Accordingly, PMG’s policy on Conflict Minerals declares:
- PMG strives to have a Conflict Free supply chain, and is committed to sourcing products and materials from non-conflict sources;
- PMG expects that its suppliers have processes in place to trace their materials and products to ensure that Conflict Minerals contained in products do not originate from mines within the DRC and the surrounding region;
- To further the benefits of Section 1502 and promote its intended purpose, PMG will work with suppliers with underdeveloped processes, providing information and guidance in an attempt to increase supply chain transparency.
PMG provides all suppliers identified under the SEC regulations with a Reasonable Country of Origin survey. This survey must be completed by those suppliers to ensure continued eligibility to do business with PMG. Suppliers will also need to certify, in writing, that they have procedures in place to demonstrate that materials and products are sourced in accordance with PMG standards and to assure the reliability of the survey responses. Based on the survey results, PMG may require additional information from those same suppliers in order to determine whether or not a supplier’s products or materials are indeed “Conflict Free”.
PMG recognises the challenges that lie ahead in establishing reasonable practices to break through existing complexities and barriers to information throughout the Conflict Minerals supply chain. Working together, PMG and its suppliers can help establish traceability of Conflict Minerals that will promote the eradication of human rights abuses associated with DRC regional mining activities, and assurance to our end customers that our products and materials are responsibly sourced.
Authorised Signatory for PMG Company Ltd
Name: Ben Parsons
Position: General Manager