Conflict Minerals Regulation
On August 22, 2012, the final rule regarding sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“the Dodd-Frank Act”) was approved by the U.S. Securities and Exchange Commission (“SEC”). The rule imposes reporting requirements on publicly-traded companies relating to the presence of conflict minerals in the products that they manufacture.
Section 1502 of the Dodd-Frank Act designates cassiterite,
columbite-tantalite (coltan), wolframite, or their derivatives, which
are limited to tin, tantalum and tungsten, respectively, and gold as
“conflict minerals.” These minerals are used in many manufactured
goods across many industries, including the aerospace, appliances,
automotive, electronics, jewelry, medical and tool and die industries.
Trane Technolgies is committed to taking all reasonable steps to
comply with the legislation and has begun the lengthy process of
determining where conflict minerals exist within our direct material
Overview of the Conflict Minerals Issue
The SEC’s conflict mineral rule focuses on the Democratic Republic
of the Congo (“DRC”), a central African country with vast mineral
wealth, including reserves of conflict minerals. For many years, armed
groups have fought to control mines within the DRC and smuggle
minerals out of the country, the proceeds of which are used to finance
conflict and perpetuate criminal behavior. These armed groups have
been cited for committing multiple human rights violations and
contributing to the humanitarian crisis in the region. The new
reporting requirements reflect Congressional concerns that the
exploitation and trade of conflict minerals by armed groups is helping
to finance conflict in the DRC region.
Publicly traded companies are now required by the SEC to disclose annually whether conflict minerals necessary to the functionality or production of products they manufacture or contract to manufacture are “DRC conflict free.” According to the SEC’s final rule, this means that any conflict minerals used in manufactured products that originated from the DRC, Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, or Zambia (the “Covered Countries”) did not directly or indirectly finance or benefit armed groups within these countries.
In addition to the conflict minerals listed above, the U.S. Secretary of State may, from time to time, designate as a conflict mineral any mineral the Secretary finds to be financing conflict in the Covered Countries.
Trane Technolgies' Approach to Conflict Minerals
The SEC’s final rule on conflict minerals applies to Trane
Technolgies suppliers of products and materials that are incorporated
into Trane Technolgies' products, regardless of where the supplier is
located. Trane Technolgies will seek to responsibly source materials
from the Covered Countries and to avoid supporting the armed groups
causing human rights violations. Thus, Trane Technolgies expects our
- source conflict minerals responsibly and to provide sufficient
data , including supporting due diligence records, demonstrating
they have ensured that, to the extent they use conflict minerals in
the products they provide to Trane Technolgies, the procurement of
those conflict minerals does not support these armed groups and are
DRC Conflict Free;
- establish conflict minerals
compliance policies, survey their suppliers and establish a due
diligence process to support their conflict minerals data collection
- document thoroughly their efforts to determine the source of any conflict minerals or derivatives and be prepared to provide Trane Technolgies with evidence of the origin of any conflict minerals contained in products supplied to Trane Technolgies.
At this time, Trane Technolgies uses the standard EICC/GeSI template to survey its suppliers, which includes use of the Conflict Free Smelter list. Trane Technolgies encourages its suppliers to do the same.
Suppliers who cannot provide this data demonstrating that conflict minerals used in their products provided to Trane Technolgies are DRC Conflict Free may not be considered for future projects with Trane Technolgies. A supplier’s failure to cooperate with Trane Technolgies to provide the necessary data may result in termination of the buyer/supplier relationship by Trane Technolgies. Similarly, providing data that shows the armed groups are being supported by material purchased for Trane Technolgies products can result in termination of the buyer/supplier relationship by Trane Technolgies.
Form SD and Conflict Minerals Report
- 2019 Form SD and Conflict Minerals Report
- 2018 Form SD and Conflict Minerals Report
- 2017 Form SD and Conflict Minerals Report
- 2016 Form SD and Conflict Minerals Report
- 2015 Form SD and Conflict Minerals Report
- 2014 Form SD and Conflict Minerals Report
- 2013 Form SD and Conflict Minerals Report
If you have questions or feedback regarding our Conflict Minerals program, please contact ConflictMinerals@tranetechnologies.com.