Policy & Compliance
> Policy & Compliance

Conflict Minerals Compliance

The mining of certain raw materials especially in the Democratic Republic of the Congo and its adjoining countries finances the ongoing armed conflict in those areas.

In these locations, militia commit the most grievious human rights violations in their efforts to control the mines and sell the extracted "conflict minerals" (such as gold, tantalum, tungsten, and tin - "3TG minerals") across the globe.

A number of companies are obliged by law to issue reports indicating whether and to what extent 3TG minerals have been procured from the conflict region. The aim of this is to ensure that, in future, only conflict-free 3TG minerals are bought and traded. In particular, this is to be achieved by means of a system of certified smelting.

U.S. Gear respects the objective of this principle, to prevent the financing of militant groups who commit human rights violations, and pledges its commitment to achieving this objective. U.S. Gear is working towards only using conflict-free 3TG minerals in its own products and, within this context, explicitly endorses the establishment of the Responsible Minerals Assurance Process (RMAP) of the Responsible Minerals Initiative (RMI).

U.S. Gear Corp. Policy for Sourcing Conflict Minerals

All suppliers to U.S. Gear corp. support this policy by:
  1. Being diligent in their assessment and validation of their supply chains to ensure the objectives of a transparent supply chain and conflict-free purchases are supplied to the services and products produced.
  2. Be in compliance at all times with all regional and international regulations for conflict minerals.
  3. Be in compliance at all times with industry standards for the sourcing and reporting of conflict minerals.
  4. Being diligent and accurate in the formal assurances of conflict-free minerals provided.

Reasonable Country of Origin Inquiry (RCOI)

Our RCOI included to:
  1. Identify our suppliers who provided us with materials containing 3TG and then use the Conflict Minerals Reporting Template (CMRT) developed by the Responsible Minerals Initiative (RMI) to facilitate transparency of the supply chain regarding 3TG sourced from the smelters and refiners.
  2. Confirm with our suppliers that they are in compliance with our conflict minerals policy and their covenant to disclose the source information of the smelters and refiners under the representation letters.

Due Diligence (DD)

The Due Diligence (DD) measures to conform to the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the "OECD Guidance"). It adopted the OECD Guidance to identify/assess supplier risks and mitigate these identified risks.

Conflict Mineral Management

U.S. Gear communicates conflict mineral policies to our suppliers through formal documentation or website. Suppliers are required to comply with US Gear's conflict minerals policy and establish their own conflict minerals policies and to their own suppliers. The policy also requires suppliers to actively assess and validate their supply chain, and encourage them to source minerals from Smelters or Refiners (SoRs) that have received "conflict-free" designations by the Responsible Minerals Assurance Process (RMAP), or other independent third party audit program.