Responsible Minerals Sourcing

There are a number of raw materials in electronics, including various mined minerals. While most of our supply chain interactions are with suppliers who work with smelters, we are committed to sourcing our minerals in an ethical and sustainable manner – and that means looking all the way back to the mines.

Mining is an intensive process, and some operations in conflict-affected and high-risk areas have been linked to human rights violations including child labor, labor abuses, and environmental degradation. This is especially true for tin, tungsten, tantalum and gold (often referred to as 3TG or “conflict minerals”) that could originate from certain mines which are controlled by armed militias who use the proceeds from the sale of these minerals to fund ongoing conflict. Additionally, there is growing concern about the conditions associated with mining other minerals like cobalt, used in the manufacture of lithium-ion batteries, which has been linked to human rights abuses.

For Dell, the issue is clear: we support and respect the human rights of all people. Responsible sourcing is a critical part of upholding those rights for employees and workers in our supply chain. It’s Dell's policy to refrain from purchasing from any known sources whose sale directly or indirectly finance armed conflict or contribute to human rights abuses. We expect the same of our suppliers.

Collaborating across the industry

These are complex issues that require a multidisciplinary approach. Early on, we convened a summit of our peers, suppliers and other stakeholders to address the risks associated with mining operations in conflict-affected and high-risk areas. We helped create the Conflict-Free Sourcing Initiative (now known as the Responsible Minerals Initiative), whose programs, tools, and guidance documents help companies address responsible sourcing issues for minerals in their supply chains.  We participate in various RMI working groups to collaborate and gain deeper understanding on emerging topics.

Working with our suppliers

Dell’s Supplier Principles, which are referenced in our standard contracts and purchasing agreements, require direct materials suppliers to have a conflict minerals policy of their own and to conduct due diligence on the source and chain of custody of the 3TG in their products. As part of this, we have worked to map the movement of 3TG and cobalt through our supply chain and we maintain a publicly available list of 3TG smelters and refiners as part of our Responsible Minerals Sourcing Report.

Based on our risk assessments and third-party auditing, we work with our suppliers, offering resources and education on best practices in due diligence. In particular, we urge a shift to smelters or refiners that are conformant with the Responsible Minerals Initiative’s Responsible Minerals Assurance Process (RMAP) assessment protocols.

While we continue to refine our risk assessments, we are focused on removing smelters and refiners of concern from our supply chain. Smelters and refiners identified as presenting higher risk and having low probability of remediation are prioritized for removal from our supply chain.

Conflict-free, not Congo-free

While “conflict minerals” are directly linked to the Democratic Republic of the Congo, not all mining activity in the Congo is corrupted by non-state armed groups or human rights violations. We intend to be “DRC Conflict-Free,” not “DRC-free,” and therefore we support responsible sourcing from the Covered Countries in order to support peaceful economic activity in the region.

If our suppliers’ responsible mineral sourcing policies specifically state an intent not to source from central Africa, we provide feedback on how to improve those policies and clear any misconceptions that could actually contribute to a drop in trade of conflict-free minerals from the region.
Conflict Minerals