2020 Conflict Minerals

Posted by Jeff Kirchner on Oct 23, 2020 3:36:28 PM
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As required by the Conflict Materials provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act, HR 4173, Section 1502 (Conflict Minerals Act), many companies, including many of our customers, are required to make disclosures regarding whether “conflict minerals” used to manufacture their
products originated in the Democratic Republic of Congo or the adjoining countries.

These “conflict minerals” consist of tantalum, tin, gold and tungsten (collectively, the “Conflict Minerals”).

High Performance Alloys, Inc. (HPA) has completed a reasonable country-of-origin inquiry of currently approved suppliers who have provided or will continue to provide raw materials on or after January 31, 2013.

Based on our inquiry, HPA can confirm that all currently-approved, raw material suppliers have provided statements confirming their compliance with the law. HPA will also ensure new raw material suppliers seeking approval provide conflict minerals statements of compliance as a requirement of approval.

HPA declares that due to the complexity of the routes by which metals, and in particular precious metals, are smelted, recycled, and sold, including the common practice of commingling ores and scrap from many different sources, it is often impossible for any company to obtain full traceability to an exact origin of all
materials. Regardless, we assure our customers that:

  • HPA will not knowingly purchase raw material supplies containing conflict minerals, and
  • HPA will take practical action to ensure that conflict minerals do not enter our supply chain

You may download our CMRT version 6.01 here.


Thank you for the opportunity to address your concerns regarding this new regulatory matter. You may download this statement here.

Topics: regulations

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