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Conflict Minerals

Conflict Minerals Overview

Conflict minerals are the minerals such as the tin, tantalite, tungsten, gold, etc. which are extracted from the Democratic Republic of the Congo or adjoining countries which are involved in conflicts.

In relation to conflict minerals, in July 2010, a law requiring reporting on the use of conflict minerals (Dodd-Frank Financial Reform Act). Following the passage of the US Congress, it is mandatory to the SEC (Securities and Exchange Commission) whether to use conflict minerals from 2014 to May 31 of each year. It is required to report on the use of conflict minerals and to disclose information to companies listed on the US stock market.

As a result, US stock market listed companies as well as domestic companies that supply products to listed companies are affected by this regulation.

In addition, the EU enacted relevant regulations (No. 2017/821) in 2017 and prohibited the import of conflict minerals, which took effect on January 1, 2021.

LSAT Responsible Supply Chain Management Policy

LSAT is based on honesty and transparency in corporate activities, and we are concerned with the regulation of conflict minerals, an international issue.

  • We will establish conflict minerals business process to comply with international standards and laws governing conflict minerals.
  • We will participate in Prohibition of the use of conflict minerals promoted by EICC and the Global e-Sustainability Initiative (GeSI).
  • We will receive document of “Declaration of Conformity for Unused Conflict Minerals” from all suppliers so that this policy can be expanded.
  • We will not tolerate or benefit from anti-human or anti-social behavior, and will not contribute for those.
  • We do not purchase products containing conflict minerals and do not supply any products to domestic and overseas corporations/factory, etc. We will strive to continuously maintain and improve the conflict minerals policy by reflecting international laws, governmental organizations, and customer policies.
Conflict Mineral Areas

Supplier requirements and measures for conflict minerals management policy

Suppliers are responsible for setting up the documented conflict minerals management policy procedures so that conflict minerals are not included to the armed forces of the Democratic Republic of the Congo or its neighboring countries.

Suppliers shall make good faith efforts to identify all the names and locations of all smelters where conflict minerals were purchased in the supply chain.

Suppliers shall take corrective actions in a timely manner when a risk in the supply chain is discovered.

In relation to conflict minerals, if there are any of the following reasons, we may refuse or suspend the transaction with the relevant suppliers.

  • In case the supplier does not provide sufficient information to confirm the use of conflict minerals, or if different information from the facts is provided.
  • In case the supplier has a relationship with the other party related to the items mentioned below or other illegal items. Torture, abuse, human rights violations, coercion, forced labor, child abuse, violations of liberty, war crimes, violations of international humanitarian law, crimes against humanity, genocide, etc.

We will jointly respond with our business partners for systematic supply chain management, and monitor the government’s policies and support. We will establish a gradual process along with responding to conflict minerals regulations. We will actively participate in global activities to prevent the use of conflict minerals.