In August 2012, the U.S. Securities and Exchange Commission adopted Rule 13p-1 under the Securities Exchange Act of 1934, as mandated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, to require companies to publicly disclose their use of conflict minerals in products they manufacture or contract to manufacture.
Conflict minerals originate in the Democratic Republic of Congo (DRC) or a neighboring country, and are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (3TG). The intent of the rule is to curb violence and human rights abuses in the DRC and its neighboring countries that may be fueled by the proceeds from the sale of conflict minerals.
Booz Allen is committed to responsibly sourcing minerals. We will not knowingly provide support to, contribute to, assist with, or facilitate armed conflict in the DRC. We will follow due diligence procedures relating to conflict minerals which are consistent with a nationally or internationally recognized due diligence framework which may include the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance).
We expect our suppliers to adopt a similar policy or position and to meet the expectations set out below. Where our suppliers do not source directly from smelters, we expect the suppliers to pass this requirement on to their supply chain to assist in determining the source of the conflict minerals.
Tin, tantalum, tungsten, and gold may be necessary to the functionality of the products Booz Allen manufactures or contracts to manufacture, and, in those cases, Booz Allen will strictly adhere with the rule’s reporting requirements. Where Booz Allen engages a third-party manufacturer or component supplier, we will flow-down the rule’s due diligence, monitoring, and reporting obligations to our partners. We are working with our supply chain to increase transparency regarding the origin and traceability of minerals contained in our products.
