Dodd-Frank Section 1502 - Conflict Minerals

 

Form SD (2017)
Form SD (2016)
Form SD (2015)
Form SD (2014)

 

Background:

Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") in response to the housing market collapse and financial recession beginning in 2008. Section 1502 of "Dodd-Frank" identifies certain "Conflict Minerals" defined as Tantalum, Tin, Tungsten, and Gold, commonly referred to as "3TG" (the derivatives of Columbite-tantalite (Coltan), Cassiterite, Wolframite), originating from mines under control of armed militant groups accused of human rights violations operating in the eastern Democratic Republic of Congo ("DRC") and the adjoining countries. These countries include Angola, Burundi, Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia ("DRC Region"). This legislation outlines new reporting requirements and additional filings to be made by U.S. publicly traded companies with the U.S. Securities and Exchange Commission ("SEC") and disclosure must contain information about such Conflict Minerals originating from the DRC Region.

Astec Policy:

Astec Industries, Inc. and its Subsidiaries ("Astec Industries") support ending the violence and human rights violations in the mining of Conflict Minerals and is committed to supporting the responsible sourcing of Conflict Minerals from the DRC region. Our core values state that we promote honesty and integrity in all aspects of business and have the utmost respect for all individuals. Accordingly, Astec Industries has adopted a "Conflict Minerals Policy" and expects its suppliers to meet these expectations.

Suppliers Expectations:

Based on our core values listed above, Astec Industries considers all of its suppliers its partners in order to comply with the new Dodd-Frank reporting regulations. In order to verify compliance with the Astec Industries policy, it is necessary for all suppliers to complete Astec Industries' questionnaire entitled "Astec Conflict Minerals Reasonable Country of Origin Inquiry". Astec Industries utilizes the Electronics Industry Citizens Coalition (EICC) format to conduct its supply chain inquiry along with an electronic data management system for collection and processing. Suppliers shall submit their responses electronically. An email will be sent to any new supplier, which will include instructions and a link to either a downloadable Microsoft Excel spreadsheet, or a web form. Astec Industries also expects that:

  • Suppliers will not include in any products sold to Astec Industries or any of its subsidiaries, any Conflict Minerals mined in the DRC Region that fund armed conflict, and if the supplier is initially unable to determine the source of the minerals in its products, it will make its best effort to determine the source as soon as possible.
  • Suppliers will develop Conflict Minerals policies, due diligence frameworks, and management systems, consistent with the Organization for Economic Cooperation and Development (OECD) guidelines and to drive those efforts throughout their supplier chain.
  • To the extent available, suppliers will use CFSI designated Conflict-Free Smelters as the source for any of the Conflict Minerals that are mined in the DRC region and used in the products sold to Astec.

Astec Industries expects its supplier partners to promote an environment of respect for all individuals worldwide and to operate in a manner that imposes honor and integrity in all aspects of business. Only companies who comply with Astec Industries above stated policy will be considered for the supply of components or materials that are incorporated into any final product, manufactured or contracted to be manufactured, by Astec Industries.

As recommended by the OECD Due Diligence Guidance, Astec has established a grievance mechanism as a risk-awareness system for conflict minerals issues. Stakeholders can communicate directly and confidentially with our compliance officer at This email address is being protected from spambots. You need JavaScript enabled to view it.