Conflict Minerals Compliance Leadership

Global Advanced Metals (GAM) is a world leader in tantalum exploration, mining and processing. GAM produces ethically sourced tantalum powders and metallurgical products at its Pennsylvania, USA and Aizu, Japan plants for a range of industries, including: electronics, aerospace, automotive, defense, medical, additive manufacturing, and chemical processing. GAM is committed to responsible minerals trade and the promotion of worldwide responsible supply chains for tantalum.

GAM joined the Conflict-Free Smelter Program—CFSP (now Responsible Minerals Initiative—RMI) in 2009 to promote legal, ethical and responsible minerals mining and trade. The RMI is comprised of leading companies throughout the electronics and other industries who have developed and implemented an audit process to help companies source minerals responsibly, and meet their legal and corporate responsibility objectives. As an active member of the RMI, GAM’s processing sites in Boyertown Pennsylvania, USA. and Aizu Wakamatsu, Japan were the first to successfully participate in the CFSP (now known as the Responsible Minerals Assurance Process—RMAP) audit in 2010 and have since maintained their “RMI-conformant smelter” status.

As a smelter, GAM adheres to the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRA). Through the OECD Due Diligence Guidance and RMI-RMAP audit GAM is committed to supporting compliance with conflict minerals due diligence requirements as detailed by section 1502 of the U.S. Dodd Frank Act and its related Security and Exchange Commission (SEC) implementation rules, the European Union regulation on conflict minerals, and other applicable regulations.

The due diligence program for conflict minerals at GAM includes the following:

• • Implementation of the Standard Operating Procedure (SOP) for tantalum material acquisition that meets upstream and downstream compliance requirements, within the framework of our management system.
• • Communication GAM due diligence expectations to suppliers via our Conflict Minerals Policy (link) and Supplier Code of Conduct (link).
• • Successful completion of the RMI-RMAP audit under the new audit standard with expended requirements for Conflict-Affected and High-Risk Areas (CAHRAs)
• • Cooperation with organizations and agencies such as the RMI, OECD, iTSCi of the International Tin Research Institute (ITRI), and the Public Private Alliance for Responsible Minerals Trade (PPA) to establish credible and effective processes for conflict-free tantalum mining and trade, and allow continuation of legitimate minerals’ activities in “conflict regions.”
• • Support of ongoing efforts by relevant organizations like the PPA and OECD that have the potential to ensure legitimate, socially responsible commerce and bring sustainable improvements and economic stability in “conflict regions”.
• • Compliance with applicable legislation such as the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act (July, 2010) which encourages legitimate and conflict-free trade of minerals sourced from the Democratic Republic of the Congo (DRC) and the Great Lakes Region of Africa.
• • Interview with US Government Accountability Office (GAO) in support of their Dodd-Frank 1502 requirement to report annually on industry compliance.
• • Integration of conflict-free due diligence requirements within contract terms with suppliers
• • Assurance that all purchases from “conflict regions” such as the DRC and the Great Lakes Region of Africa, comply with the applicable requirements of the OECD Due Diligence Guidance for Responsible Supply Chains and its Annex II Risks.
• • Assurance that all shipments to GAM of tantalum containing material adhere to the appropriate domestic and international transportation regulations, including requirements for Class 7 material.
• • Communication of GAM ethical and sustainable sourcing practices to our suppliers, employees, and customers, and internal monitoring of our performance to these standards.
• • Visits to tantalum mine sites and suppliers to support due diligence and compliance efforts. These visits enable GAM to further assess upstream supply chain risk and devise appropriate risk mitigations as needed.
• • Providing RMI’s Conflict Minerals Reporting Template (CMRT) to customers to support their Reasonable Country of Origin Inquiry (RCOI) as required under SEC rules.

GAM leadership in conflict minerals compliance and source development fosters stable and ethical supply chains that support business’ needs and meet sustainability-ESG goals across the myriad industries it supports.