Conflict Minerals Compliance
Conflict Minerals Compliance
Conflict Minerals refer to tantalum, tin, tungsten, gold (3TG), and other minerals from the Democratic Republic of Congo and its neighboring countries, where the armed groups use forced labor, human right abuses, and other illegal means to mine, sell and fund weapons, causing regional unrest. Tantalum, tin, tungsten, and gold are minerals necessary for the functional operation of electronic products. In order to fulfill the social responsibility of human rights and environmental protection, USI has placed a conflict-free mineral procurement policy, and promises not to use conflict minerals, and requires suppliers to gradually purchase minerals from conformant smelters to reach a conflict-free supply chain and customer requirements.
Conflict Minerals Management
In order to avoid the inadvertent use of conflict minerals in the manufacturing process of our products, the Company has established a conflict minerals procurement management policy that commits to not using conflict minerals and requires suppliers to source raw materials from Qualified Smelters Disclosed by RMI and to sign and commit to comply with the conflict minerals procurement management policy of USI to achieve the Company's conflict minerals-free supply chain and customer requirements.
USI follows the OECD”Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas”, the five-step framework to establish a management system. USI conducts due diligence by identifying and assessing risks, then respond and mitigate the risks through the supply chain. In addition, USI creates a supplier conflict mineral audit checklist and supports the suppliers to establish a management mechanism that meets with the OECD due diligence guidance through on-site or document audits.
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Management System |
Identify and Assess Risk |
Respond to identified Risk |
Conduct third party audit |
Report annually on Due Diligence |
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Reasonable Country of Origin Inquiry (RCOI)
USI conducts RCOI and promotes the procurement of conflict-free minerals from the supply chains each year. At the same time, expanding the scope of supply chains, to collect and assess the source origin of the 3TG and cobalt smelters from the conflict regions or the conflict-affected and high-risk areas (CAHRAs). Key materials adopted by USI come from qualified smelters, the 3TG and cobalt smelters distribution in recent years is illustrated in the tables below:
3TG and Cobalt from Qualified Smelters Distributions:
| Year | 2019 | 2020 | 2021 | 2022 | ||||||||
| Materials/ Status |
Conformant | Active1 | Non-Participating | Conformant | Active | Non-Participating | Conformant | Active | Non-Participating | Conformant | Active | Non-Participating |
| Tantalum | 40 | 1 | - | 39 | - | - | 39 | - | - | 36 | - | - |
| Tin | 77 | 2 | - | 73 | - | - | 55 | 12 | - | 60 | 5 | - |
| Tungsten | 43 | 2 | - | 45 | 2 | - | 42 | 6 | - | 39 | 1 | - |
| Gold | 104 | 1 | - | 110 | 1 | - | 109 | 6 | - | 102 | 7 | - |
| Cobalt | 2 | 11 | 64 | 9 | 12 | 52 | 22 | 15 | 38 | 33 | 9 | 1 |
USI continues to promote the procurement of conflict-free minerals to the supply chain, and expanded supply chain due diligence. In 2022, a total of 199 suppliers completed the CMRT (Conflict Minerals Reporting Template) survey. In addition to 3TG, we are progressively including more minerals from Conflict-Affected and High-Risk Areas (CAHRAs) (e.g., cobalt and mica) in the survey, with a total of 150 suppliers surveyed and disclosed for cobalt and mica, response rate reached 100%.
Number of Qualified Suppliers:
| Year | 2019 | 2020 | 2021 | 2022 |
|---|---|---|---|---|
| Number of suppliers that completed due diligence | 352 | 359 | 416 | 199 |
Independent Private Sector Audit and Public Disclosure
1.Every year , USI undergo IPSA2 on the results of supplier due diligence and our target supplier3 used 100% only from qualified smelters.
2.USI as a subsidiary of ASEH, discloses conflict minerals investigation results through ASEH annal Conflict Minerals report filing to the US Security and Exchange Commission. For complete Conflict Minerals report:
2. IPSA, Independent Private Sector Audit.
3. Target suppliers are the top 90% of suppliers according to the annual purchase amount and the suppliers for the top customer of the year.
Regard the ASE Technology Holding Co., Ltd. Corporate Policy for Sourcing Conflict Minerals. Please refer to the link.
Future Plans
USI utilizes the resources and guidance provided by RMI and OECD to implement measures to respond to conflict minerals in the supply chain. Suppliers are required to refer to RMI conformant smelter lists to meet USI's target to a conflict-free minerals supply chain.
- 1. Continue to conduct supplier assessment, and guide suppliers to establish management mechanisms.
- 2. Optimize supplier management system to improve the management of smelter information quality, while achieving customers' reporting requirements.
- 3. Set up a plan to investigate the sources of cobalt and mica to meet RMI and Responsible Minerals Assurance Process (RMAP) standards.
- 4. Communicate USI's management and investigation requirements through supplier conferences.
Conflict Minerals Contact
If you have any questions, comments or suggestions regarding conflict minerals program, please contact: conflict_minerals@usiglobal.com
