Ethical sourcing includes avoiding the use of conflict minerals, including those financing the ongoing violence and humanitarian crisis in the Democratic Republic of Congo (DRC).
Understanding Our Responsibility
In 2012, the U.S. Securities and Exchange Commission (SEC) finalized the Conflict Minerals rule, which was originally mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Section 1502), in an effort to further the humanitarian goal of ending violent conflict in the DRC and the adjoining region, which is partly funded by the mining of conflict minerals. As a result, publicly traded companies governed by the U.S. SEC must report annually on whether their products contain minerals (tin, tantalum, tungsten and gold or “3TG”) that were sourced in the DRC or a neighboring country.
These minerals are mainly used by the electronics industry but could be found in our supply chain. We have implemented policies and practices to identify conflict minerals and their sources, and to meet U.S. SEC requirements.
In accordance with the U.S. SEC rule, Hasbro provided a conflict minerals disclosure form, confirming that in 2015 we manufactured, and contracted to manufacture, products containing 3TG. We also conducted a Reasonable Country of Origin Inquiry (RCOI) to determine if these necessary conflict minerals were sourced from African countries covered by the U.S. SEC rule. All direct suppliers and third-party contract manufacturers of products believed to contain 3TG were surveyed about the source of these minerals.
Based on our RCOI, we were unable to determine that our necessary conflict minerals did not originate in the Covered Countries or are not from recycled or scrap sources. Our full Conflict Minerals Report for 2015 can be found online.
Vendor Support Training
We continue to build programs and processes to increase visibility into our supply chain, identify the sources of conflict minerals used in our products and to improve capabilities within our supply chain. Our efforts include providing training on conflict minerals for active and new vendors, and encouraging vendors to source from smelters designated as conflict free.