Conflict Minerals Policy


The term 'conflict minerals' refers to the metal materials tin, tungsten, tantalum and gold, from the Democratic Republic of Congo and its neighboring countries. These materials are also referred to as the 3TG. Trading 3TG from the Democratic Republic of Congo and its neighboring states enables armed conflict and human rights abuses. The EU-Regulation 2017/821 and U.S. Dodd‐Frank Wall Street Reform and Customer Protection Act, Section 1502 and SEC regulations require disclosure of the use of 3TG and transparency within the supply chain. The idea behind this is to end armed conflicts and heed international law. In line with the requirements of the EU-Regulation 2017/821 and Dodd‐Frank Act, HOERBIGER is aware of its responsibility and is contributing at various levels to sustainably protect human rights. HOERBIGER is committed to ensuring the health, safety and protection of the people who extract and mine 3TG. It is our responsibility to demand high social, environmental and human rights standards from our suppliers, too. Even though HOERBIGER is not directly affected by the EU-Regulation and Dodd‐Frank Act, compliance with these requirements in relation to conflict minerals is an immediate part of it.

Our contribution

HOERBIGER is constantly working on further increasing transparency in the supply chain and ensuring conflict‐free mining of the 3TG that we use in our products. We are thus committed to:

  • Identifying which HOERBIGER products are impacted and targeting our efforts accordingly
  • Not buying products and materials containing Conflict Minerals directly from Conflict Mines
  • Asking our suppliers to work towards ensuring that any Conflict Minerals contained in the products and materials supplied to HOERBIGER originate from Conflict Free Sources
  • Contributing to conflict-free trade by encouraging our suppliers not to discriminate against legitimate sources of Conflict Minerals

Actions taken

HOERBIGER has defined the following measures in working towards to fulfill our responsibility and ensure transparency in the supply chain:

  • Establishing a Compliance Program to review the use of Conflict Minerals in our products and to be in a position to fulfill our reporting obligations and respond to customer inquiries. This program will be based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas and other appropriate international standards
  • Requiring our suppliers also to implement a policy regarding Conflict Minerals and exercise due diligence to investigate the source of these minerals
  • Engaging our suppliers to respond to our requests for evidence of compliance. We reserve the right to review the information provided by the supplier and knowingly incorrect information will be punished up to and including termination of existing contracts
  • Updating the HOERBIGER Purchasing Terms and Conditions to reflect the content of this policy

As many other companies tracking Conflict Minerals, it will take time for a company of our size and complexity to collect the information needed for us to fully understand our use of Conflict Minerals and therefore be able to address all related customer concerns.

Version 02/2021 - HOERBIGER Corporate Purchasing