Northrop Grumman is committed to the responsible sourcing of minerals through our global supply chain. In 2012, the U.S. Securities and Exchange Commission (“SEC”) issued rules implementing the “conflict minerals” disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). Under these rules, we report annually to the SEC on our use of conflict minerals (tantalum, tin, tungsten and gold) originating in the Democratic Republic of Congo (“DRC”) or any of the DRC’s adjoining countries in products manufactured by the Company. We are committed to complying with the Dodd-Frank disclosure requirements.
Underlying the Dodd-Frank disclosure requirements is a concern that conflict minerals originating in the DRC or adjoining countries may be mined and sold by armed groups to finance civil violence. These minerals can make their way into the supply chains of the products used by consumers and businesses around the world. Tracing these minerals in the international supply chain is complex.
We are focusing our compliance efforts in the following areas:
- Conducting a reasonable country of origin inquiry with our global supply base as part of our conflicts minerals due diligence process.
- Utilizing the Organisation for Economic Co-operation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-risk Areas and, where appropriate, their five step framework for risk-based due diligence in the mineral supply chain.
- As part of this process, we collect and evaluate various supplier responses to an industry-established conflict minerals reporting template, the Electronic Industry Citizenship Coalition’s Global e-Sustainability Initiative (“GeSI”) Conflict Mineral Reporting Template.
- We request that suppliers identify products in their supply chain that contain conflict minerals and validate the country of origin of these minerals.
- Engaging, consistent with the Dodd-Frank rules, independent auditors to conduct an audit of our conflict minerals approach and processes.
We also continue to engage with trade associations both inside and outside of our industry to benchmark our processes and share best practices.
We recognize these rules have required, and will continue to require, time and effort on the part of our suppliers. We appreciate their ongoing support in this important effort. Periodic updates to Northrop Grumman’s supply chain guidance can be found on our Online Automated Supplier Information System (OASIS) website or https://oasis.northgrum.com.
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