Conflict Minerals Compliance and Re-Selling OEM Products

Question Posed:

We have a few products that contain connectors with a gold plated layer. These are off-the-shelf purchases and not custom-made. Do we need to include the connector manufacturer’s smelters on our list? What about the solders we use during product assembly?

Right now, we are only reporting against the gold and tin shot we purchase and use in the fabrication of metal layers in our devices.

Answer Provided:

There is a retailers’ exemption that may be applicable to your product. For example, if your company take the original manufacturer's product, then re-sell it under the original manufacturer's brand (doing nothing to the product), the item could be considered out of scope.  Please refer to Question 4 listed in the SEC FAQ linked in the References section below.

Reference: https://www.sec.gov/divisions/corpfin/guidance/conflictminerals-faq.htm

**Article contents valid as of 2017-08-18

 

Have more questions? Submit a request

Comments