Trimble is committed to sourcing components and materials from companies that share our values concerning human rights, ethics and environmental responsibility. On August 22, 2012 the Securities and Exchange Commission ("SEC") published final regulations implementing the "conflict minerals" reporting obligations under section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Trimble is actively implementing the procedures, systems and reporting requirements necessary to comply with these regulations.
The Dodd-Frank Act requires that all publicly traded companies subject to SEC rules report annually on the presence of certain minerals, characterized as conflict minerals, including tin, tantalum, tungsten or gold, in the products they manufacture or contract to manufacture, and demonstrate the proper level of due diligence in determining whether these minerals originated from the Democratic Republic of the Congo ("DRC") or an adjoining country or from scrap or recycled sources. The goal of the act is to cut direct and indirect funding of groups engaged in armed conflict and human rights abuses.
Trimble does not directly purchase any conflict materials. Tracing these materials back to their country of origin is a complex task that may require us to, among other things, survey suppliers in our supply chain to understand what programs they have in place for tracing the source of minerals supplied to us or used in products supplied to us and to ensure that reasonable due diligence has been performed. Trimble uses and requires its suppliers to use the Electronic Industry Citizenship Coalition (EICC)/GeSI Conflict Minerals Standard Reporting Template Tool as part of the due diligence procedures used to determine the source and chain of custody of the conflict minerals in the assemblies, parts or components they supply to us.
Trimble fully understands the importance of this issue and we will take the proper steps to ensure our continued compliance with the reporting obligations imposed by the SEC.