Conflict Minerals Policy

Updated Friday, June 12, 2015 at 13:29 EST


Disclosing Use of Conflict Minerals

Per SEC News Digest Issue 2012-163, on August 22, 2012 the Securities and Exchange Commission adopted a rule mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act to require companies to publicly disclose their use of conflict minerals that originated in the Democratic Republic of the Congo (DRC) or an adjoining country.
These rules require certain companies to disclose their use of conflict minerals that include tantalum, tin, gold, or tungsten (3T&G) if those minerals are "necessary to the functionality or production of a product" manufactured by those companies.


Conflict Minerals Act Compliance

Whip City Tool & Die Corporation (WCT) is committed to sourcing strip materials from suppliers that share our values (and our customers) around human rights, ethics and environmental responsibility in supplying conflict-free materials/parts.

Whip City Tool & Die Corporation is responsible to:

  • Due Diligence Program

    Establish a due diligence program to achieve a conflict-free supply chain from supplier's when sourcing materials that contain tantalum, tin, tungsten and gold to assure customer parts are DRC conflict-free.
  • Tin, tungsten, tantalum and gold (3T&G)

    Determine if parts supplied to customers contains tin, tungsten, tantalum and gold (3T&G).
  • Report Conflict Minerals
    Report conflict minerals and smelters to customers using the Conflicts Minerals Reporting Template (CMRT), as applicable.

    WCT is currently using iPoint Conflict Minerals Platform (iPCMP) software tool from iPointSystems.
    Available free at http://conflict-minerals.com.

    For more information visit www.conflictfreesourcing.org.
    Click to download Conflicts Minerals Reporting Template (CMRT).
  • Country of Origin
    Maintain material certifications (which include country of origin) and provide to customers, as applicable.


Strip Material Suppliers are responsible to:

  • Due Diligence Program

    Establish their own due diligence program to achieve a conflict-free supply chain when sourcing materials that contain tantalum, tin, tungsten and gold to assure it is conflict-free.
  • Conflict Minerals Policy

    Submit a conflict minerals policy to WCT and provide WCT with an electronic copy or (preferably) a link to where your policy is publically available.
  • Tin, tungsten, tantalum and gold (3T&G)

    Determine if strip material supplied to WCT contains tin, tungsten, tantalum and gold (3T&G).
  • Report Conflict Minerals
    Report conflict minerals and smelters to WCT using the Conflicts Minerals Reporting Template (CMRT). Any exception must be approved by WCT.

    For more information visit www.conflictfreesourcing.org.
    Click to download Conflicts Minerals Reporting Template (CMRT).
  • Country of Origin
    Provide DFR conflict-free materials and provide WCT with material certifications containing the country of origin. Any exception must be approved by WCT.


Changes to our Conflict Minerals Policy

If we decide to change our Conflict Minerals Policy, we will post those changes on this page, and/or update the Conflict Minerals Policy modification date below.

This policy was last modified on 10-9-2014.


Contacting Us

If there are any questions regarding this Conflict Minerals Policy you may contact us using the information below.
www.whipcitytool.com
Whip City Tool & Die Corporation
P.O. Box 99
Southwick, MA 01077-0099
USA
info@whipcitytool.com
(800)905-7909