Conflict minerals, answered.

Conflict minerals are:

• Tantalum (columbite-tantalite or coltan) — used in electronics for capacitors
• Tin (cassiterite) — used in most solder
• Tungsten (wolframite) — may be found in lasers and chemical labs
• Gold — many uses, but heavily used in printed circuit boards

Sometimes these are referred to as 3T's & G, or 3TGs.

These minerals are called out in The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), Section 1502. "Conflict" refers to the fact that these minerals, sourced in the Democratic Republic of the Congo (DRC) or an adjoining country, may be financing conflict and related human rights abuses in those regions. In addition to the DRC, the "covered countries" include: Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.

The term "Conflict Minerals" applies to Tin, Tungsten, Tantalum and Gold regardless of where they actually originate. Tin from Peru or Gold from Canada are still considered conflict minerals.

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) was signed into U.S. federal law in July 2010, and deals with major financial reforms, increasing liability among companies and aimed at preventing adverse financial events due to unethical business practices. Conflict Minerals is called out in Section 1502 of this Act.

Publicly-traded companies on the U.S. stock exchange are affected. Registrants are required to file a Special Disclosure (SD) related to Conflict Minerals and potentially provide a Conflict Minerals Report with this SD filing. Data for this filing must be gathered by suppliers and provided to these companies through a Reasonable Country of Origin Inquiry (RCOI) process. Companies must file annually by the end of May for the previous year's activities (e.g., May 2026 for 2025 reporting year).

It is the process by which a company surveys its suppliers regarding the source of conflict minerals in materials/products the suppliers have provided. The RCOI starts with the Conflict Minerals survey — see "How is data collected from suppliers?" below.

Although a private company is not required to report about 3TGs on its own behalf, if it is a supplier to a publicly-traded company required to comply with the regulation and file the disclosure and report, then that private company should provide their sourcing information as requested by the publicly-traded company.

Our customer expects suppliers to comply with its conflict minerals survey request and provide information on the survey form (see "About the CMRT Survey Form" below). As a condition of doing business, suppliers are required to provide information as per the terms described in the customer's P.O. Terms and Conditions, its Supplier Code of Conduct, and any specific language in contracts or agreements.

Data is collected by surveying suppliers, who in turn must survey their own suppliers, and so on. VeriSupply, a division of Sensitel Inc., has been engaged to assist with the surveying process. All survey-related requests are sent from the VeriSupply email domain. A letter authorizing VeriSupply to request information on the customer's behalf is included in the survey request emails.

The most commonly used survey form is the "CMRT" (Conflict Minerals Reporting Template), which you received with the survey request. It is formulated and maintained by the CFSI (Conflict Free Sourcing Initiative), an organization founded by the EICC (Electronic Industry Citizenship Coalition) and GeSI (Global e-Sustainability Initiative) — reference CFSI. This survey is considered the industry standard and is used by most surveying companies.

No, only the current version(s) of the CMRT is acceptable. We attach a current version (the version for the year's reporting) in our requests for you to fill out. Any current year's version is acceptable — the CFSI may release several versions during the year, but these are usually revisions to lists or corrections of functionality.

• Must be the current year version, as explained in Q10 above
• Must be in the Excel format in which it was provided (.xls, 1997–2003)
• PDF versions or images are not acceptable
• Must be in English (see Q12 below)

The CMRT defaults to English, but is available in 8 additional languages. On the "Declaration" tab, a pull-down at the top right lets you choose from: Chinese, French, Spanish, Japanese, Portuguese, Italian, Korean, or German.

Once a language is chosen, the Instructions, Definitions, Declaration, Smelter List, Standard Smelter Names, Checker, and Product List tabs are translated. Reminder: if you change the language to fill out the form, change it back to English before sending it back — non-English versions will be returned for correction.

Yes — there is a list for each mineral, managed and updated by the CFSI on their website. These lists may be updated as often as monthly.

Suppliers are encouraged to review the Instructions tab of the CMRT. In short, the requirements are:

• The Declaration tab, including the Company Information section and scope
• If no 3TGs are used, see Q17
• If 3TGs are used, answer Questions 1 through 7 and A through J
• The Smelter List tab — if 3TGs are used, provide smelter information
• The Product List tab — only if the declared scope/reporting level chosen is "Product (or List of Products)"

The Checker tab shows what information on the Declaration tab is missing. It's a good idea to review it before finalizing and sending the CMRT. Results appear in two places: on the Declaration tab (near the top, above "Revision") and on the Checker tab itself, where fields requiring information are shown in red, with a count near the CFSI logo.

No — only the CMRT survey meeting the requirements described in Q10, Q11, and Q12 is acceptable. Please don't send RoHS, REACH, or tax forms, as these do not apply to conflict minerals.

Yes — this "no 3TG" information is still captured using the CMRT, and confirms your status as "responded" rather than "no response," fulfilling your obligation per PO Terms & Conditions and the Supplier Code of Conduct.

If no 3TGs are used, fill in:

• The Company Information section (fields highlighted in yellow, marked with an asterisk "*")
• Questions 1 and 2 for all minerals

Once Questions 1 and 2 are complete, the remaining questions should auto-populate and complete the Declaration.

Yes, if you provide materials containing the minerals. If you're declaring no 3TGs (per Q17 above), you don't need to answer these questions.

All documents and communications should be sent back to the requesting email address included in your survey request, or to info@verisupply.com.