Tenneco Statement on Conflict Minerals
Tenneco is committed to sourcing components and materials from companies that share our values around human rights, ethics and environmental responsibility. On August 22, 2012, the final rule regarding sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act was approved by the U.S. Securities and Exchange Commission ("SEC").
The rule imposes reporting requirements on certain companies to perform due diligence with respect to the sourcing of conflict minerals and to file annual reports relating to the use of conflict minerals (tantalum, tin, gold or tungsten) originating in the Democratic Republic of the Congo and certain adjoining countries ("Covered Countries") in the products they manufacture or contract to manufacture if the conflict minerals are necessary to the functionality or production of a product. Reports must be filed with the SEC on or before May 31st for the previous calendar years in scope products.
to see Tenneco's current report for the 2018 calendar year.
Tenneco is committed to taking steps to comply with the legislation and has implemented a due-diligence process to meet its obligations. Tenneco supports an industry-wide approach to addressing social responsibility issues throughout the supply chain and participates in the Automotive Industry Action Group (AIAG) and is using the Organization for Economic Cooperation and Development (OECD) Guidelines as a framework for its due diligence. The benefit of this approach is that the industry can look at these issues more strategically and holistically than any individual company.
In order to comply with the legislation and manage customer requests regarding conflict minerals, Tenneco has and plans to continue the following:
- Educate its suppliers with respect to the requirements on conflict minerals.
- Use an industry-wide identified approach to develop a centralized means of collecting, tracking and responding to customer requests.
- Assess its products and identify those for which conflict minerals are or may be necessary to their functionality or production.
- Develop processes to determine if such necessary conflict minerals originated in the Covered Countries or to confirm that they are from recycled or scrap sources. This will include supporting the Conflict-Free Smelter Program developed by the Electronic Industry Citizenship Coalition, Incorporated ("EICC") and Global e-Sustainability Initiative ("GeSI") and obtaining information and assistance from suppliers to trace the origin of any necessary conflict minerals.
- Based upon the information gathered utilizing the processes developed, prepare appropriate disclosure for Tenneco’s Form SD and, if required, its Conflict Minerals Report.
Tenneco expects its suppliers to conduct similar due diligence on the sources and chains of custody of these minerals and make their due diligence findings available to Tenneco.
Grievance Mechanism and Reporting
Concerns or reports of possible violations of this statement can be reported confidentially through Tenneco's Webline or to the Board of Directors directly:
Suppliers and other external parties also are encouraged to contact us at firstname.lastname@example.org
if they wish to seek guidance on this statement or if they wish to report concerns.