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Trimble Conflict Minerals Resources

Trimble adopted the Responsible Business Alliance's ("RBA") Code of Conduct for our Supplier Code of Conduct.  It is important for Trimble to source materials from companies that share our values regarding respect for human rights, ethics, and environmental responsibility.  Trimble has created this page to inform readers on our actions to address Conflict Minerals.
  • Conflict Minerals Policy and Disclosure

  • Conflict Minerals Program

  • Trimble Supplier Conflict Mineral Resources

Conflict Minerals Policy Statement

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 encourages its suppliers to use the OECD Due diligence Framework as part of the due diligence process 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.


Conflict Minerals Disclosure

Trimble's Conflict Minerals Program

Which Metals are affected by this law?

Tin, Tantalum, Tungsten, and Gold​ and its derivatives ("3TG", "Conflict Metals")

What are possible outcomes from supplier completed reports?

 There are 3 possible outcomes:

  • Undetermined, we just don't know yet
  • DRC Conflict Free
  • DRC Conflicted

Who are the suppliers in scope for Trimble's Conflict Minerals Program?

  • Suppliers who use 3TG in parts provided to Trimble
  • Tier 1 suppliers with transactions for the current year

What are the some of the basic requirements for suppliers in scope for Conflict Minerals?

  • Educate supply chain with regards to Conflict Minerals or practice of responsible sourcing
  • Have a Conflict Minerals Policy (or Sourcing Policy)
  • Collect information using the CMRT from their 3TG suppliers
  • Provide an updated CMRT free of errors and duplicates when requested as part of Trimble’s Conflict Minerals Program
  • Conduct due diligence or reasonable country of origin inquiry ("RCOI")  to determine the origin of the 3TG
  • Source from smelters Compliant (or working towards compliance) with the Responsible Minerals Assurance Process (“RMAP”) or similar program

Supplier Standards and Rquirements
Click the image for more information on Trimble's Supplier Requirements

What are the expectations for Trimble’s CMRT collection? 

  • In scope suppliers are required to provide their updated CMRT before the end of the year.  Initial CMRT can be provided, but a final CMRT must be provided before the end of February.
  • In scope Suppliers are expected to use the latest version of the CMRT downloadable in RMI's website:  http://www.responsiblemineralsinitiative.org/conflict-minerals-reporting-template/
  • In scope suppliers CMRT are expected to provide a complete and accurate CMRT that is free of duplicate smelters
  • In scope suppliers are expected to provide more information for smelters not part of the CMRT smelter list.

How does Trimble identify a smelter as a "high risk"

  • Smelters located in the DRC and its nine adjoining countries
  • Smelters with audit status of Non-Conformant
  • Smelters not interested in participating in the RMAP or similar program for compliance
  • Smelters with history on unethical business practice and sourcing activities or linked with news on the possibility of contributing conflict in regions and violating human rights

What are expected for in-scope suppliers with high risk smelters?

Click image for the
OECD due diligence
  • Inform their suppliers regarding the high risk smelters 
  • Verify if the product delivered to Trimble contains the 3TG
  • Identify the suppliers for the products delivered to Trimble and check if their CMRT contain the high risk smelter. 
  • Inform Trimble on the result of your initial verification
  • If verified to not use the high risk smelter, provide Trimble an updated CMRT which excludes the high risk smelter
  • If verified to contain the high risk, provide Trimble an action plan that you can commit to ensure responsible sourcing

What is the next step for in scope suppliers who verified using the high risk smelter?

  • Implement your action plan and update Trimble on the progress
  • Work with your supply chain to remove the smelter in the next reporting
  • Use RMI’s Smelter Engagement letter to push your supply chain to reach out to the high risk smelter and motivate the smelter to comply
  • Find an alternate source or work with your supply chain to find an alternate source to remove the high risk smelter

Trimble aligned its Conflict Minerals Program with the company’s Code of Conduct and adopted the Responsible Business Alliance's ("RBA") Code of Conduct  for our Supplier Code of Conduct and a member of RBA’s Responsible Minerals Initiative("RMI").

EICC Tracing materials back to their mine of origin is a complex but critical requirement of responsible sourcing in the electronics supply chain. The RBA and RMI are taking action to address material sourcing through the development of the Responsible Minerals Assurance Process (RMAP). For more information click on the icon to the left to be taken to the website.

compliance icon 2RMIRBA

Click the left image to taken to RMI’s site where you can download the latest version of the CMRT.  Click on the right images to be directed to RBA and RMI website

Please send all responses along with your completed CMRT or other conflict minerals documents to conflict_minerals@trimble.com.  Should you have any questions concerning Trimble's request for the reporting of conflict minerals or need assistance in completing the CMRT please contact conflict_minerals@trimble.com.

3TGOECDClick the left images to view our supplier training slides for Conflict Minerals.  Click on the right image to be directed to the OECD website.