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Addressing Conflict Minerals

Many industries rely on certain minerals that are mined in conflict regions or under strenuous environmental conditions to produce their products. These minerals include cassiterite, wolframite and coltan, which are ores that contain tin, tantalum and tungsten, respectively. Because such metals are used in many products — electronics, vehicle air bag systems, airplanes, jewelry and X-ray film — the demand for them is great.

The Democratic Republic of Congo (DRC) in Central Africa is one of the places in the world where these natural resources can be found and mined in abundance. The DRC has been mired in a brutal conflict since 1998, and the resulting hostilities and human rights abuses are largely fueled by the trade of these "conflict minerals."

Tin mining in Indonesia on the islands of Bangka and Bilitung has been criticized for lack of regulations and monitoring, environmental damage and poor labor conditions.

 

It is Dell’s position to source responsibly, to work collaboratively with others to create conditions where we can give our customers confidence that we are acting responsibly and to hold our suppliers accountable to the same high standard.

Our approach to responsible sourcing and supplier accountability

As a manufacturer of products that contain gold, tantalum, tin and tungsten, Dell is committed to operating in a socially responsible way. It’s Dell's policy to refrain from purchasing from any known conflict sources and we expect that our suppliers adhere to the same standards. We have notified all our suppliers of our policy on conflict minerals and have asked each supplier to provide us with a confirmation of their conflict-free status.

Dell also works diligently to educate suppliers, investors and customers on this issue through speaking engagements, workshops and stakeholder engagements.
Conflict Minerals
The complexities of the metal supply chain pose many challenges. The mining of these minerals takes place long before a final product is assembled, making it difficult, if not impossible, to trace the minerals' origins. In addition, many of the minerals are smelted together with recycled metals and at that point, it is virtually impossible to trace the minerals to their source. Another challenge is the informal nature of the DRC’s minerals economy. Tracing the source of these minerals — from mine through smelter to final product — is a complex challenge that we cannot address alone.

We’re engaged with the Electronics Industry Citizenship Coalition (EICC), an organization devoted to improving social and environmental conditions in electronics supply chains, to develop a process that companies can use to track the origin of these minerals regardless of the industry they will be used in. In 2011, the EICC launched the Conflict-Free Sourcing Initiative (CFSI), which tracks documentation from the smelter back to the mine of origin.

Dell has been involved in many other efforts to bring us closer to a conflict-free supply chain. In 2009, Dell commended U.S. Rep. Jim McDermott on the introduction of the Conflict Minerals Trade Act in the House of Representatives. Dell supported the goals of this bill and has long embraced transparency and procurement from a socially and environmentally responsible supply chain. In fall of that year, we reached out to our competitors and invited them to join us in issuing a call to action to other industries that use these minerals in their final products.

In October 2010, we hosted an international multistakeholder event on conflict minerals. The conference, which was tied to the Corporate Responsibility Officers (CRO) Summit in Paris, convened leaders from the IT industry, NGOs and the Organization for Economic Co-operation and Development (OECD) to drive other industries to take action on responsible sourcing.

Dell continues to collaborate within our industry and with others on this important issue. Industry research indicates that the electronics industry is responsible for only about 30 percent of the global usage of these minerals. The more industries that agree changes are needed to address conflict minerals, the greater the potential for marketplace incentives to drive those changes.

Dell commends Congress and the SEC for delivering the final rule for Dodd-Frank section 1502

Long ago we started our journey to enable responsible sourcing through our complex supply chain. We have been building internal processes in anticipation of the new requirements. It is our goal to support and encourage conflict-free sourcing for every industry. Dell is actively participating in the EICC, which is developing industry agnostic tools to further this goal.

Over the coming weeks we will be evaluating the rule for impact to our business and suppliers, making adjustments as necessary to prepare us for the upcoming disclosure requirements.

Beyond our supply chain: A timeline of steady progress in promoting collective action

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Dell is working toward the goal of responsible sourcing globally, including from the DRC, through a conflict-free supply chain, confirmed by a robust verification system.

We have been actively involved in the CFS process from the beginning and more recently in the PPA.

Once the CFS program and certification programs have matured to a point that Dell is confident in its ability to deliver conflict-free materials, we will begin to require suppliers to use certified sources for procurement in Dell products.

Dell is committed to working with other industries, the government and NGOs to collaborate on a solution to purchase conflict-free minerals and minerals mined from environmentally responsible sources as well as to help implement this solution. Dell will continue to participate in the industry conversation, proactively seek solutions and encourage everyone who has a final product that contains these minerals to join us in these efforts. Beyond responsible sourcing, we think about the big picture when it comes to supplier standards and accountability.