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.
U.S. Conflict Mineral Reporting Regulation
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 rules require each public company, for which conflict minerals are necessary to the functionality or production of one or more products that it manufactures or contracts to manufacture, to perform due diligence on its supply chain in an effort to determine how those minerals are sourced. Further, such companies must annually report and make public whether any conflict minerals originate from the Democratic Republic of Congo or adjoining countries (together, the “Covered Countries”). Reports must be filed with the SEC on or before May 31st for the previous calendar years in scope products. For additional details, please review the conflict minerals final rule, available at: http://www.sec.gov/rules/final/2012/34-67716.pdf
European Union Conflict Minerals Regulation.
The EU Regulation, as agreed by the EU Institutions, is set to ensure sustainable sourcing for more than 95% of all EU imports of tin, tantalum, tungsten and gold, and is covered by due diligence provisions as of 1 January 2021.
Paving the way for the EU regulation in May 2017, the European Parliament and the Council of the European Union issued Regulation (EU) 2017/821 laying down diligence requirements in the supply chain for Union importers of Tin, Tantalum and Tungsten, their ores, and gold, originating in conflict areas or at high risk areas. The regulation was signed into law in June 2017. The requirements for EU importers apply from 1 January 2021.
The EU regulation aims to ensure that EU importers of 3TG (tin, tungsten, tantalum and gold) meet international responsible sourcing standards, set by the Organization for Economic Co-operation and Development (OECD); ensure that global and EU smelters and refiners of 3TG source responsibly; help break the link between conflict and the illegal exploitation of minerals; and help put an end to the exploitation and abuse of local communities, including mine workers, and support local development.
Tenneco supports an industry-wide approach to addressing social responsibility issues like conflict minerals throughout the supply chain and actively works with the Automotive Industry Action Group (AIAG), customers and suppliers to further the awareness of conflict in Covered Countries and Conflict-Affected and High-Risk Areas (CAHRAS).
We participate in cross-industry initiatives to develop common tools and practices that support the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAS) published by the Organization for Economic Co-operation and Development (OECD) see http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf Tenneco will continue to evaluate our policies and collaboration with industry groups while applying the OECD due-diligence process as part of our compliance effort.
View the current version of the Conflict Minerals Reporting Template
It is Tenneco’s expectation that its suppliers will adopt policies and procedures with respect to conflict minerals that will enable us to reasonably assure products supplied to Tenneco are conflict-free. In order to comply with the legislation and manage customer requests regarding conflict minerals, Tenneco has and plans to continue to:
- Educate its suppliers with respect to conflict mineral requirements.
- 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 Responsible Business Alliance ("RBA") and Global e-Sustainability Initiative ("GeSI") and obtaining information and assistance from suppliers to trace the origin of any necessary conflict minerals.
- 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.
- Tenneco may request due diligence be performed following the same process and procedures as defined by OECD framework on additional minerals of concern to make a reliable determination of the origin and source of such minerals.
(Many customers are requiring reporting on Mica, Cobalt and more. RMI has developed a template for Extended Minerals Reporting template for Cobalt and Mica https://www.responsiblemineralsinitiative.org/reporting-templates/emrt/. The Pilot Reporting Template is for additional minerals https://www.responsiblemineralsinitiative.org/reporting-templates/prt/)
Grievance Mechanism and Reporting
Concerns or reports of possible violations of this statement can be reported confidentially through Tenneco's Webline:
- Via Webline: www.tennecohotline.ethicspoint.com
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.