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Our products, like virtually all consumer electronics, contain various metals, including tantalum, tin, tungsten and gold, (3TG) which originate in mines around the world. The 3TG metals have become known as ‘conflict minerals’ because they are in part sourced from Eastern provinces of the Democratic Republic of Congo (DRC) where a decade-long civil war is continuing. Illegal armed groups control mines and transit routes to fund their violent operations.
In the U.S. the Dodd-Frank Act requires companies to file annual reports with the U.S. Securities and Exchange Commission (SEC) beginning 31st May 2014, indicating if they are using 3TG originating from the DRC or adjoining countries. A likely but unintended consequence of this regulation is a widespread withdrawal from trade with the DRC by U.S. companies.
Motorola Mobility believes it is essential to establish validated, conflict-free sources of 3TG within the DRC and elsewhere so that these minerals can be procured in a way that contributes to economic growth and development in the region rather than to conflict. We are willing to partner with governmental organizations, industry groups and NGOs to achieve a solution.
A more complete briefing on conflict minerals is available from the NGO The Enough Project.
A useful training presentation is available from the Electronic Industry Citizenship Coalition (EICC): EICC-GeSI training deck.
Motorola Mobility is implementing a due diligence program to identify and trace the 3TG minerals in our supply chain, based on the procedures and tools provided by the EICC and the Organization for Economic Co-operation and Development (OECD). We are members of the EICC Extractives Work Group and Due Diligence Work Group. The current status of our due diligence program is as follows:
1. Tracing 3TG in our supply chain using the EICC Mineral Reporting Template
We have adopted the EICC standardized reporting template and are requiring our suppliers to use this template as well. Currently, we have sent the template for completion to all of our production suppliers. We will integrate that data into an EICC tool documenting the overall progress of our supplier compliance program. We will continue to add supplier information to this database as they respond. To enhance accuracy and efficiency of the tracing process we have engaged Source Intelligence (formerly Source 44), a supply chain data management company, to facilitate supply chain tracking. Source Intelligence enables independent 3rd party mapping of selected suppliers and confirms which are using certified smelters.
Under the Motorola Mobility Supplier Code of Conduct and EICC code of conduct for responsible sourcing of minerals, suppliers shall exercise due diligence on the source and chain of custody of minerals used the manufacturing of their products, and make their due diligence measures available to customers upon request. See more details at http://eicc.info/initiatives02.shtml.
2. Identifying the smelters in our supply chain
Our suppliers should source only from certified conflict free smelters. To accomplish that objective, we are identifying the smelters in our supply chain based on the information gathered through the EICC reporting template. The Conflict Free Smelter Initiative maintains a list of smelters that have been certified as conflict free. We hope to see the process of certification proceed more quickly.
Motorola requires its suppliers to adhere to the OECD Due Diligence Guidance and we follow the guidance in our own due diligence program.
3. Dodd Frank compliance
Motorola Mobility will be fully compliant with the SEC reporting requirements before the deadline for submission of 31st May 2014.
4. Solutions for Hope
In 2012, Motorola Mobility became a participant in the Solutions for Hope (SfH) Project, led by major capacitor manufacturer AVX Corporation. The SfH pilot project was launched in July of 2011 to test the feasibility of a closed-pipe supply line approach in the responsible sourcing of tantalum. The pilot project achieved the first validated source of conflict-free tantalum ore from the DRC and has been instrumental in proving that a conflict-free mineral supply chain is feasible in the country. SfH now works to promote the economic stability of the DRC through the continued expansion of conflict-free mineral supply chains throughout the region. Motorola Mobility continues to support the project and intends to purchase conflict-free tantalum capacitors for use in our products as they become available.
5. NGO engagement
The Enough Project ranks the efforts of companies to eliminate conflict minerals from their supply chains. Motorola Mobility is included in the top tier of electronic companies for progress toward responsible sourcing of conflict minerals in Enough’s 2012 publication “Taking Conflict Out of Consumer Gadgets: Company Rankings on Conflict Minerals 2012”
Motorola Mobility encourages individuals or suppliers who wish to report possible violations of our conflict minerals policy to contact us via one of the following channels:
By logging concerns at motorolamobility.ethicspoint.com.
By calling, toll free:
In the U.S., Canada or Puerto Rico: call +1 866-839-5946
Outside the U.S. and Canada: visit motorolamobility.ethicspoint.com for dialing instructions from your country.
Or by writing to:
Office of Ethics and Compliance
600 N U.S. Highway 45
Libertyville, IL 60048 U.S.
Submissions are strictly confidential and multiple languages are supported. We investigate all allegations of ethical misconduct and take corrective action when claims are substantiated.
Tin Mining in Bangka, Indonesia
Motorola Mobility has a comprehensive and aggressive conflict minerals traceability program. Legitimate concerns have recently been raised regarding possible environmental and economic damage from tin mining on Bangka Island, Indonesia. Motorola Mobility understands and shares the goal of addressing such harm and is participating in efforts to address it.
Bangka is a major supplier of tin, which is widely used in the global consumer electronics industry. Motorola Mobility recognizes that suppliers in our global supply chain may potentially use Bangka tin. As a result we are working diligently with our suppliers to confirm the country of origin of tin used to produce our components. We are also working with the EICC, which has established a working group to address tin mining, and with other entities such as local governments, smelters and NGOs with the goal of reaching meaningful assurances that tin mining on Bangka Island is done in an environmentally and socially responsible manner.
Further information on our supply chain policies can be found in our supplier code of conduct.
Motorola Mobility Goals
|Goals for 2013||Actions in 2013||Goals for 2014|
|Continue to monitor parts and products that contain 3TG.||Completed a detailed assessment and identified where tin, tantalum, tungsten and gold are used in our products.||Summarize 3TG part and product compliance data for 2013. Comply with Dodd-Frank reporting requirements.|
|Obtain supplier level EICC declarations for all suppliers whose products contain 3TG.||We have surveyed all of our production suppliers and they declared if the metals they provide originate in the DRC or adjoining countries.||Obtain supplier level EICC declarations for suppliers whose annual spend is >10K and their products contain 3TG. Refresh any supplier declarations >1yr old.|
|Upgrade IT solution for conflict minerals management enabling product level assessments to Dodd-Frank for Motorola Mobility products and meeting requisite reporting requirements.||Designed an IT solution that integrates into our environmental data management system (WPA). IT solution upgrade work started 4Q13.||Implement WPA M20 IT solution for conflict minerals in 1Q14. Transition to the use of the IPC 1755 Conflict Minerals Data Exchange Standard.|