As a company with sales and manufacturing operations throughout the world, Dana Incorporated (“Dana”) supports the sourcing of minerals responsibly, as set out in the Standards of Business Conduct. We support ending the violence and human rights violations in the mining of certain minerals from a location described as the “Conflict Region”, which is in the Democratic Republic of the Congo (“DRC”) and neighboring countries. As a result, the U.S Securities and Exchange Commission (“SEC”) adopted final rules to implement reporting and disclosure requirements related to “conflict materials”, as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The rules require manufacturers who file certain reports with the SEC to disclose whether the products they manufacture or contract to manufacture contain “conflict minerals” that are “necessary to the functionality or production” of those products.
- Mines and smelters outside the “Conflict Region” or
- Mines and smelters which have been certified by an independent third party as “conflict free” if sourced within the “Conflict Region”
Dana is basing its due diligence processes, in part, on the guidance provided by the Organisation for Economic Co-operation and Development (“OECD”). The framework of the OECD provides practical guidance to companies on a set of actions that can be taken throughout its supply chain to ensure responsible due diligence. Dana has established a global team, reporting to executive leadership, to work through the OECD framework and is developing a plan to address each of its focus areas.
This due diligence includes having our suppliers provide written evidence documenting that raw materials used to produce gold, tin, tantalum and tungsten, used in the materials to manufacture components and products supplied to Dana Holdings Corporation, originate from outside the “Conflict Region” or if they originate from within the “Conflict Region”, that the mines or smelters be certified as “conflict free” by an independent third party. The aim is to ensure that only “conflict free” materials and components are used in products that we procure.
If we discover the use of these minerals produced in facilities that are considered to be “non-conflict free”, in any material, parts or components we procure, we will take appropriate actions to transition the product to be “conflict free”.