Regulatory Policies

Conflict Minerals Legislation

Guidelines & Strategy

Summary of Conflict Minerals Legislation

Dodd-Frank Wall Street Reform and Consumer Protection Act, also known as the Conflict Minerals law is contained in Title XV, sections 1502 and 1503. The final rule was signed and issued by Security and Exchange Commission (SEC) on August 22, 2012.

The rule is applicable to publicly traded companies. These companies are required to file annual reports with the SEC. The first report is due May 31, 2014, covering calendar year 2013.

Some publicly traded companies are requesting information from their supply chain well before the May 31, 2014.

European legislators are drafting similar legislation.

Dodd-Frank legislation defines “conflict minerals” as the ores Cassiterite, Columbite-Tantalite, Wolframite and Gold.

Cassiterite is the mineral ore for Tin (Sn)
Columbite-Tantalite is the mineral ore for Tantalum (Ta)
Wolframite is the mineral ore for Tungsten (W)
Gold (Au)
These 4 metallic elements are also referred to as 3TG.


Guidelines & Strategy

MetoKote Corporation has developed these guidelines and strategy to support its customers in the event some of the materials we use contain any chemical elements regulated by the Conflict Minerals legislation. The information obtained through this process is intended to support MetoKote customers comply with their Conflict Minerals Report (CMR) requirements.

MetoKote Corporation guidelines and strategy are based on the following principles:

  1. Understand rules and their applicability
  2. Develop a list of target US based material suppliers with the technology potential to include any of the 3TG elements
  3. Submit written requests to the target US based material suppliers
  4. Use the EICC report format to make the requests to material suppliers and to report requested information to customers
  5. Ask targeted suppliers to provide the requested information on a product specific basis if any of the 3TG elements are used in any materials supplied to MetoKote.
  6. Track and evaluate information requests made to material suppliers
  7. Ask other material suppliers to provide information, where applicable, due to customer needs.
  8. Empower the Corporate Technology and EHS departments to lead and implement the guidelines and strategies.
  9. Create a specific and dedicated email address to send and receive information requests conflictminerals@metokote.com
  10. Create a master folder file in the “T” drive to store and track all information related to the conflict minerals.
  11. Communicate with all MetoKote operating plants to make sure they understand the requirements and that they forward all customer requests to the above departments for processing.

Target US based material suppliers

  • PPG Industries
  • Henkel Americas
  • Chemetall NAFTA
  • Akzo Nobel
  • Dupont
  • Sherwin Williams
  • Valspar
  • TCI
  • Tiger Drylac
  • IVC Industrial Coatings
  • Patriot Paint

Written Request for Information to Suppliers

MetoKote Corporation is making this information request to your company in an effort to aid our customers in meeting the Securities and Exchange Commission (SEC) reporting requirements such as the Conflict Minerals Report (CMR).

We ask that your company completes the attached EICC/GeSI excel sheet and that you respond to us by October 31, 2013.

We also ask that if your answer YES to question 1) of the questionnaire that you must further specify the product code or codes that contain the covered metals by changing the declaration scope to D: Product Level and completing the tab named Product List.

The response must be emailed to conflictminerals@metokote.com and include the completed excel form as an attachment. The response must also provide the contact name, phone number and email address of the person responsible in your organization for responding to this request.

Be aware that if your supplied products contain any of the target metals listed in question 1), you are also required to provide the additional information requested in Sections 2) thru 6) as to the country of origin of the mining and smelting operations supplying the listed metals to you.

We appreciate your prompt response and your cooperation in helping our customers comply with this regulatory matter.

If you have any questions or need any additional information, please let us know. You can reach us by responding to this email or by calling us at 419-996-7800 and asking for the Conflict Minerals compliance department.