Conflict Minerals Compliance
Conflict Minerals Compliance
Conflict Minerals refer to tantalum, tin, tungsten, gold (3TG), and other minerals from the Democratic Republic of Congo and its neighboring countries, where the armed groups use forced labor, human right abuses, and other illegal means to mine, sell and fund weapons, causing regional unrest. Tantalum, tin, tungsten, and gold are minerals necessary for the functional operation of electronic products. USI utilizes RMI's resources and guidance to make responsible choices regarding conflict minerals, protecting human rights and the environment through sustainable procurement, and achieving a conflict-free mineral supply chain.
Conflict Minerals Management
USI has developed a procurement policy for conflict minerals aligned with the overall Group1 policy. We pledge to refrain from utilizing conflict minerals and mandate our suppliers to procure conflict-free minerals exclusively from smelters or refineries accredited by an independent third-party audit program. This rigorous process is designed to eliminate the use of metals originating from the Democratic Republic of the Congo, its neighboring countries, or other high-risk regions. Our company insists that suppliers acquire raw materials from smelters disclosed by RMI, requiring them to sign and commit to complying with USI's conflict minerals procurement management policy. This ensures the establishment of a conflict-free supply chain in line with both regulatory standards and customer expectations.
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Furthermore, we strictly adhere to the OECD Due Diligence Guidance Annex II, implementing a model supply chain policy for responsibly sourcing minerals from Conflict-Affected and High-Risk Areas. USI firmly pledges not to support mineral sourcing linked to severe human rights violations. We enhance our supply chain risk mitigation plan and expect suppliers to procure conflict-free minerals from smelters or refineries certified through an independent third-party audit program. This commitment ensures that our supply chain not only complies with regulatory requirements but also upholds the principles of human rights and ethical responsibility.
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USI according to OECD”Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas”, the five-step framework to establish a management system. USI conducts due diligence by identifying and assessing risks, then respond and mitigate the risks through the supply chain. In addition, USI creates a supplier conflict mineral audit checklist and supports the suppliers to establish a management mechanism that meets with the OECD due diligence guidance through on-site or document audits.
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Management System |
Identify and Assess Risk |
Respond to identified Risk |
Conduct third party audit |
Report annually on Due Diligence |
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Reasonable Country of Origin Inquiry (RCOI)
USI conducts RCOI and promotes the procurement of conflict-free minerals from the supply chains each year. At the same time, expanding the scope of supply chains, to collect and assess the source origin of the 3TG and cobalt smelters from the conflict regions or the conflict-affected and high-risk areas (CAHRAs). Key materials adopted by USI come from qualified smelters, the 3TG and cobalt smelters distribution in recent years is illustrated in the tables below:
3TG and Cobalt from Qualified Smelters Distributions:
| Year | 2020 | 2021 | 2022 | 2023 | ||||||||
| Materials/ Status |
Conformant | Active2 | Non-Participating | Conformant | Active | Non-Participating | Conformant | Active | Non-Participating | Conformant | Active | Non-Participating |
| Tantalum | 39 | - | - | 39 | - | - | 36 | - | - | 34 | 1 | - |
| Tin | 73 | - | - | 55 | 12 | - | 60 | 5 | - | 66 | 2 | - |
| Tungsten | 45 | 2 | - | 42 | 6 | - | 39 | 1 | - | 33 | 0 | - |
| Gold | 110 | 1 | - | 109 | 6 | - | 102 | 7 | - | 91 | 3 | - |
| Cobalt | 9 | 12 | 52 | 22 | 15 | 38 | 33 | 9 | 1 | 18 | 0 | - |
USI continues to promote the procurement of conflict-free minerals to the supply chain, and expanded supply chain due diligence. In 2023, a total of 219 suppliers completed the CMRT (Conflict Minerals Reporting Template) survey. In addition to 3TG, we are progressively including more minerals from Conflict-Affected and High-Risk Areas (CAHRAs) (e.g., cobalt and mica) in the survey, with a total of 175 suppliers surveyed and disclosed for cobalt and mica, response rate reached 100%.
Number of Qualified Suppliers:
| Year | 2020 | 2021 | 2022 | 2023 |
|---|---|---|---|---|
| Number of suppliers that completed due diligence | 359 | 416 | 199 | 219 |
Independent Private Sector Audit and Public Disclosure
1.Every year , USI undergo IPSA3 on the results of supplier due diligence and our target supplier4 used 100% only from qualified smelters.
2.USI as a subsidiary of ASEH, discloses conflict minerals investigation results through ASEH annal Conflict Minerals report filing to the US Security and Exchange Commission. For complete Conflict Minerals report:
2. Undergo RMAP-eligible third party assessment and review process audit.
3. IPSA, Independent Private Sector Audit.
4. Target suppliers are the top 90% of suppliers according to the annual purchase amount and the suppliers for the top customer of the year.
Regard the ASE Technology Holding Co., Ltd. Corporate Policy for Sourcing Conflict Minerals. Please refer to the link.
Conflict Minerals Contact
If you have any questions, comments or suggestions regarding conflict minerals program, please contact: conflict_minerals@usiglobal.com
