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Conflict Minerals

3TG Conflict Minerals

Conflict Minerals legislation arose from an amendment to the financial regulation laws in the United States of America in 2010, known as the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2009. In summary, all US companies that have to file their yearly finance reports with the Securities Exchange Commission (SEC) had to start reporting on whether their source for 4 substances is from a conflict-free source.

The 4 substances are:

  • Tantalum (Columbite-tantalite ore, or coltan)
  • Tungsten (Wolframite ore)
  • Tin (Casserite ore)
  • Gold

These four are sometimes referred to as 3TG (in reference to their initials).

The main area of conflict mines (i.e. mines that are being used to support internal conflict in a region) is in the eastern region of the Democratic Republic of Congo, along with the nine neighboring countries. Further information can be found on the website for the Responsible Minerals Initiative (previously called the Conflict Free Sourcing Initiative or CFSI).

Harwin’s position

Our current company policy statement on Conflict Minerals is available here.

Harwin do not report to the SEC, and as such are not required to submit a conflict minerals report to the US Government. However, because of the global interconnected supply chain, we are asked to report on our conflict mineral status.

Harwin use the industry standard Conflict Minerals Reporting Template (CMRT), released by the Responsible Minerals Initiative (formerly the Conflict Free Sourcing Initiative). Our Company CMRT is available from the Legislation page - second item listed. The Company CMRT is also linked to each product page, under Environmental Compliance:


Currently, Harwin has not located any conflict minerals in our supply chain. We will continue to pursue the information from our suppliers and repeat these investigations on a regular basis. If you have any questions on this topic, do please contact [email protected] for assistance.


Cobalt is at the early stages of being considered an additional Conflict Mineral. Currently Harwin do have some uses of Cobalt within our products - most notably as a very small, but intentionally added, substance within our Gold and Zinc plating finishes.

Even though there are no regulatory compliance requirements for Cobalt in place at this time, Harwin is engaging with our suppliers to ensure that any Cobalt used within Harwin products is sourced responsibly. We are aware of the Cobalt Reporting Template (CRT) published by the Responsible Minerals Initiative, and are currently considering how this can be best utilised within Harwin and our supply chain.

Work is in progress and we will report here when there is further information. If you have any questions on this topic, do please contact [email protected] for assistance.


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