Conflict Minerals, Due Diligence
Responsible Sourcing of Conflict Minerals
In several countries around the world, the mining of certain minerals is believed to be supporting armed groups, conflicts and crimes against the civilian population. The main minerals involved, known as ‘conflict minerals’, are Tin, Tantalum, Tungsten and Gold, also known as “3TG”, as well as Mica and Cobalt.
As a consequence, since 2012, Section 1502 of the Dodd-Frank Act regulates the use of conflict minerals. In the European Union, a similar law, Regulation 2017/821 of May 17, 2017, establishes supply chain due diligence obligations for importers of minerals from conflict-affected areas and high-risk areas.
Legrand is committed to buying from responsible and trusted sources, and forbids sourcing minerals that contribute to armed conflict or human rights abuses in conflict-affected and highrisk areas, including the Democratic Republic of Congo (DRC) and adjoining countries.
Legrand’s approach is to promote traceability and transparency amongst the supply chains from suppliers to customers to promote and reinforce a conflict-free global supply chain.
Legrand supports the RMI Responsible Minerals Initiative
Legrand supports the Responsible Minerals Initiative (RMI), using standard processes designed to obtain chain of custody declarations from all relevant suppliers to ensure sourcing transparency.
Legrand is committed to communicating to its customers the information known about its supply chain related to conflict minerals.
Legrand Conflict Minerals Reporting (CMRT)
Legrand Expanded Conflict Minerals Reporting (EMRT)
Legrand asks its suppliers to commit
As a responsible player, the Group supports OECD initiatives by following the recommendations of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
Legrand requires all its suppliers to comply with applicable regulations on conflict minerals.
Suppliers are requested to put in place traceability for these minerals to prevent a sourcing from conflict-affected and high-risk areas. Legrand Legrand supports its purchasing teams and suppliers in a process of continuous improvement and encourages its suppliers to apply the same principles to their own value chain.
• Respect Legrand Group’s Supplier Code of conduct , in which this Conflict Minerals policy is included;
• Compliance with purchasing specifications and general terms and conditions
• Follow the OECD Due Diligence Guidance and put in place controls to monitor the origin of minerals purchased;
• Provide duly completed CMRT and EMRT templates, designed by RMI;
• Exercise due diligence regarding the source and chain of custody of restricted minerals and make such due diligence available to us upon request;
• Passing this requirement through their own supply chain and determining the source of the specified minerals.
Legrand expects its suppliers to comply with these rules and to submit to the required verification audits. If no corrective action is taken and the suppliers fail to engage in a compliance process; Legrand may proceed with their progressive removal from its supplier portfolio.
Monitoring Process for the concerned Suppliers
The process includes the following steps:
- Assess and address conflict minerals as part of our global risk management process.
- Monitor suppliers that have not responded to Legrand's requests for information.
- Prioritize high-risk smelters based on the following criteria: geographic risk as defined by Dodd-Frank Section 1502 and EU Regulation 2017/821, third-party audit of due diligence, and evidence of any other red flags supported by credible third-party sources.
- Review all responses received from suppliers and request additional information from suppliers providing responses deemed insufficient, implausible, incomplete, inaccurate, or requiring clarification.
- Compare smelters identified by the supply chain survey to the list of facilities that have received a "conflict-free" designation from the RMI or other independent organizations.
- Provide periodic progress reports to the Group Purchasing and CSR departments, summarizing risk mitigation efforts.
- Review and assess opportunities for improving our conflict minerals compliance process.
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