A&F Co. supports the goal of the Dodd-Frank Wall Street Reform Act to prevent armed groups from benefitting from the sourcing of conflict minerals, including tantalum, tin, gold and tungsten, from the Democratic Republic of Congo and the covered countries. To achieve this goal, and to assist A&F in complying with its obligations under the Act, it is necessary that our suppliers investigate the source of any conflict minerals in the products and materials they sell to us and avoid the purchase of conflict minerals from sources that benefit armed groups in the covered countries.
Read more from Abercrombie & Fitch’s Conflict Minerals Policy below:
In 2010, Congress passed the Dodd-Frank Act, which issued rules requiring certain companies to disclose their use of conflict minerals if those minerals are “necessary to the functionality or production of a product” manufactured by those companies. Under the Act, those minerals include tantalum, tin, gold and tungsten.
Congress enacted Section 1502 of the Act because of concerns that the exploitation and trade of conflict minerals by armed groups is helping to finance conflict in the Democratic Republic of the Congo and surrounding countries (Angola, Burundi, Central Africa Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia) (“covered countries”) and is contributing to an emergency humanitarian crisis.
Abercrombie & Fitch Co. (“A&F”) supports the goal of the Act to prevent armed groups from benefitting from the sourcing of conflict minerals from the Democratic Republic of Congo and the covered countries. To achieve this goal, and to assist A&F in complying with its obligations under the Act, it is necessary that our suppliers investigate the source of any conflict minerals in the products and materials they sell to us and avoid the purchase of conflict minerals from sources that benefit armed groups in the covered countries.
A&F expects all vendors and suppliers to:
- Purchase materials from legitimate sources not involved in funding conflict;
- Avoid the use of conflict minerals which may, directly or indirectly, finance or benefit armed groups in the Democratic Republic of the Congo or covered countries;
- Confirm and verify that materials purchased are conflict-free, based on personal knowledge, reliable written representations and certifications, or other verifiable evidence provided by the supplier of items containing conflict minerals; and
- Cooperate with A&F’s “Due Diligence” process that was established by A&F to comply with the Act’s conflict minerals provisions.
The Due Diligence Process
Due Diligence is a process in which A&F (with the cooperation of its vendors) must systematically gather information about its supply chain and report data pertaining to the source of its conflict minerals, as required by the Act. A&F follows the due diligence guidelines approved by the Organization for Economic Cooperation and Development (OECD), and will have its process audited if and as required by the Act. A&F’s Due Diligence process is summarized below.
Step 1 – A&F must determine if conflict minerals are used in its products and determine if the conflict minerals are necessary to the functionality or production of its products.
Step 2 – A&F, or a third party representing A&F, will contact and survey applicable vendors and attempt to determine the following:
- The minerals country of origin including the origin of the mine and smelter
- Can the vendor confirm the minerals used did not originate in the covered countries or are from scrap or recycled sources?
- Does the vendor have any reason to believe that the minerals originated in the covered countries or may not be from scrap or recycled sources?
Step 3 – Vendors should be prepared to fully answer the survey questions from Step 2. In the event the vendor does not know how to respond, A&F Sourcing will contact the vendor to determine the next course of action.
Step 4 – A third party representing A&F, will review the information and documentation supplied by the vendor.
Step 5 – A&F will generate a Conflict Minerals Report if and as required by the Act. In the report, the results of the vendor survey will be disclosed. (Note: The names of our vendors will remain confidential.)
Step 6 – A&F is required to publish the results of its due diligence and any Conflict Minerals Report required by the Act on A&F’s Website.
The Due Diligence process will occur on an annual basis.