Partnering on conflict minerals disclosures
In order to complete the required annual conflict minerals disclosure, per the requirements of the U.S. Securities and Exchange Commission (SEC), ITW relies on its more than 300 contacts within its businesses to connect with their suppliers to gather, aggregate and report conflict minerals information.
ITW Ark-Les, a New Berlin, Wisconsin-based manufacturer of switches, sensors and connector systems, is one of those businesses. It has played a key role in engaging with its suppliers and providing insight back to the conflict minerals team to help with continuous improvement in this process.
Completing the disclosure process requires materials manager, Matt Ebert, to gather necessary information for nearly 500 parts from approximately 40 suppliers. Working closely with ITW’s corporate conflict minerals team, Ebert sends out requests to suppliers who provide metals or other parts that may contain conflict minerals.
Additionally, Ebert has had the opportunity to learn more about the suppliers’ process firsthand. “Our business works with a supplier down the road from our facility, and when they called me with questions, I was able to go to the supplier’s site and directly engage in discussions about conflict minerals, review their operation and walk them through our reporting needs for conflict minerals,” Ebert explains.
Ebert shared that it was helpful to view the facility, and learn firsthand what the supplier is required to do in this level of reporting. “It enabled me to help other suppliers, both inside and outside my own business, by sharing what I learned,” Ebert said.
While collecting the data for conflict minerals reporting involves thousands of supplier declarations, the process continues to improve. Ebert can attest to ITW’s improvement focus. “Each year, the training gets better and the process goes smoother. We’re always learning more to help engage suppliers, streamline how we gather information and more effectively complete the disclosure process,” said Ebert.