“Conflict Minerals” refers to Gold, Casserite (Tin), Columbite-tantalite (Tantalum), and Wolframite (Tungsten) or their derivatives mined in “Covered Countries”, which include the Democratic Republic of Congo (DRC) and in the adjoining countries (Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia). They are referred to as “Conflict Minerals” because revenues arising from their extraction and processing may be directly or indirectly financing armed groups engaged in civil war resulting in serious social and environmental abuse in the Covered Countries. In 2010, the U.S. Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act, pursuant to which the U.S. Securities and Exchange Commission (SEC) issued rules requiring publicly listed companies in the United States to make disclosures under specific circumstances concerning the use of “Conflict Minerals”.
Accuride Corporation (“Accuride” or the “Company”) fully supports the humanitarian goals of the Dodd-Frank Act. As a manufacturer of steel wheels, aluminum wheels, and wheel-end components for the commercial vehicle industry, Accuride does not directly purchase raw Conflict Minerals from any source and is many levels removed from the mines, smelters and refiners that produce the metals used in the products we manufacture. Accuride is nonetheless committed to working with its suppliers to educate them on these matters and on steps they can take to obtain increased transparency regarding the origin of Conflict Minerals contained in the products or materials they sell to Accuride.
This Policy Statement reflects Accuride’s commitment and its expectations for its product and raw material suppliers regarding the use of Conflict Minerals.
Accuride has the following expectations of its suppliers:
Accordingly, Accuride’s Suppliers will be expected to:
Accuride monitors and evaluates its relationships with its suppliers on an ongoing basis. Accuride reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy Statement and reserves the right to request additional documentation from its suppliers regarding the origin of any Conflict Minerals included in any products sold to Accuride. Suppliers who do not reasonably comply with this Policy Statement will be reviewed by Accuride’s supply chain organization in order to determine whether they will be allowed to continue to do business with Accuride and whether any necessary remedial steps must be taken to be allowed to continue as a supplier to Accuride and its business units.
Interested parties may report concerns and alleged violations of this Policy Statement as follows:
Reports may be made anonymously and will be kept confidential to the fullest extent practicable. No retaliatory action will be taken against any party who makes a report in good faith.
Our suppliers are encouraged to contact us via any method outlined above if they wish to seek guidance on the application of this Policy Statement.
Accuride reserves the right to amend or revise this Policy Statement at any time.
Accuride Corporation is fully committed to fulfilling its obligations regarding Conflict Minerals and supports the humanitarian goals and objectives underlying the Dodd-Frank Act provisions and SEC rules related to Conflict Minerals. Accuride will support its customers in their Conflict Minerals compliance efforts and is committed to undertake initiatives that work towards a DRC Conflict Free supply chain. Accuride encourages all of its suppliers to support these efforts.