Responsible Minerals Commitment
Responsible Minerals Commitment
Conflict minerals refer to tantalum, tin, tungsten, and gold (3TG), as well as other minerals sourced from the Democratic Republic of the Congo (DRC) and its adjoining countries, where armed groups may finance their activities through mining and trading operations involving forced labor, human rights abuses, and other unlawful practices. Tantalum, tin, tungsten, and gold are essential minerals used in the manufacture and operation of electronic products. USI complies with the Dodd-Frank Wall Street Reform and Consumer Protection Act and the European Union Conflict Minerals Regulation and is committed to protecting human rights and the environment through responsible and sustainable sourcing practices while striving to achieve a conflict-free mineral supply chain.
Responsible Minerals Management
USI strictly adhere to the OECD Due Diligence Guidance Annex II, implementing a model supply chain policy for responsibly sourcing minerals from Conflict-Affected and High-Risk Areas. USI firmly pledges not to support mineral sourcing linked to severe human rights violations. We enhance our supply chain risk mitigation plan and expect suppliers to procure conflict-free minerals from smelters or refineries certified through an independent third-party audit program. This commitment ensures that our supply chain not only complies with regulatory requirements but also upholds the principles of human rights and ethical responsibility.
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USI according to 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 | 2022 | 2023 | 2024 | 2025 | ||||||||
| Materials/ Status |
Conformant | Active2 | Non-Participating | Conformant | Active | Non-Participating | Conformant | Active | Non-Participating | Conformant | Active | Non-Participating |
| Tantalum | 36 | - | - | 34 | 1 | - | 38 | - | - | 39 | 1 | - |
| Tin | 60 | 5 | - | 66 | 2 | - | 74 | 1 | - | 56 | 5 | - |
| Tungsten | 39 | 1 | - | 33 | - | - | 36 | 1 | - | 37 | - | - |
| Gold | 102 | 7 | - | 91 | 3 | - | 95 | 4 | - | 93 | 3 | - |
| Cobalt | 33 | 9 | 1 | 18 | - | - | 76 | 3 | 39 | 60 | 2 | 34 |
USI promotes responsible mineral sourcing across its supply chain and, through its due diligence processes, requires suppliers to source from smelters and refiners validated through an independent third-party audit program. In 2025, a total of 347 suppliers3 completed the 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 225 suppliers surveyed and disclosed for cobalt, mica, nickel, copper, lithium and graphite, response rate reached 100%.
Number of Qualified Suppliers:
| Year | 2022 | 2023 | 2024 | 2025 |
|---|---|---|---|---|
| Number of suppliers that completed due diligence | 199 | 219 | 241 | 347 |
The company promotes responsible sourcing throughout its supply chain and evaluates alternative sources when necessary. Suppliers shall avoid sourcing minerals from conflict-affected and high-risk areas (CAHRAs) and shall source only from smelters/refiners that have been certified through an independent third-party audit program. If a non-conformant smelter/refiner is identified, suppliers will be required to assess the risk and transition to conformant alternative sources.
Independent Private Sector Audit and Public Disclosure
1.Every year , USI undergo IPSA4 on the results of supplier due diligence and our target supplier5 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. Undergo an eligible third-party assessment and independent review process audit.
3. The survey scope included suppliers of USI, AFG, and HCC.
4. IPSA, Independent Private Sector Audit.
5. Target suppliers are the top 85% of suppliers according to the annual purchase amount.
Conflict Minerals Contact
If you have any questions, comments or suggestions regarding conflict minerals program, please contact: conflict_minerals@usiglobal.com
