Electronic gadgets, from smart phones to networking gear and numerous other data communication products contain various metals, including tantalum, tin, tungsten and gold (3TG). These metals, which originate in mines around the world, are widely used in the components and assembly processes of consumer and enterprise electronics as well as in various other industries.
3TG metals are commonly referred to as “Conflict Minerals” because the minerals used to make tantalum, tin, tungsten and gold often originate from the Democratic Republic of the Congo (DRC), where a decade-long civil war wages on. In the DRC and surrounding countries, illegal rebel groups control mines and the trade and transit of conflict minerals to finance their violent operations.
Conflict Minerals Initiatives
Marvell supports "conflict-free" supply chains and believes it can make an impact by coordinating our supplier responsibility efforts with customers and peers as well as across sectors and industries. Marvell understands the significance of conflict-free sourcing from smelters within the DRC and surrounding countries, so that the trade of conflict-free 3TG can create sustainable economic development instead of a conflict fueled economy and country.
Marvell's initiatives to promote conflict-free sourcing of 3TG within the DRC consist of four main dimensions:
- Perform due diligence on Marvell’s supply chain
- Multi-layer approach to convey supplier responsibility expectations
- Encourage conflict-free sourcing with direct suppliers and their smelters
- Engage in and align with industry approaches to due diligence
By performing supply chain due diligence, driving accountability throughout our procurement process, promoting conflict-free supply chains and engaging in industry initiatives, Marvell will further support responsible sourcing through the electronics supply chain.
Read Marvell's Policy Statement on Conflict Minerals
Read Marvell's Conflict Minerals Report
Following the chain of custody of conflict minerals back to their mine or country of origin is a complex aspect of responsible sourcing. Due to the complexities of mineral tractability and our downstream position, we recognize it will take time, thoughtfulness and industry coordination for our direct suppliers to identify, monitor and validate the origin of conflict minerals in our supply chain.
Marvell aligns with industry practices, such as leveraging the EICC Global e Sustainability Initiative (GeSI) Conflict Minerals Reporting Template (CMRT) and participating in the Conflict-Free Sourcing Initiative (CFSI), to establish a system of controls over our supply chain and to identify processing facilities that serve as sources of supply of conflict minerals to our direct suppliers. As we survey our direct suppliers to better understand what initiatives are in place to track the source of minerals used in the products they manufacture, we cross-check information with data obtained from these industry organizations, our customers and internal investigation.
We implemented a multi-layer approach to convey our supplier responsibility expectations and our support of conflict-free supply chains to our direct suppliers through communications at various stages of our procurement process.
Since January 2013, Marvell’s Policy Statement on Conflict Minerals has been publically available to our supply chain partners. It confirms that Marvell does not support the use of conflict minerals that are illegally mined, transported or traded to fund human rights violations, social unrest, political repression or conflict or metal derived from such conflict minerals. Our Supplier Code of Conduct, which references the Policy Statement on Conflict Minerals, was sent to all direct suppliers and requested that they execute and return a Certificate of Compliance.
We also updated Marvell’s Product and Manufacturing Specifications, reinforcing supplier and product responsibility expectations through the supplier and subcontractor management procedures. As we continue to renew supplier relationships, we convey our supplier responsibility expectations, and as we enter into new supplier relationships, we confirm conformance through the vendor approval process.
Marvell supports conflict-free 3TG sourcing by promoting conflict-free compliant smelters and programs like the Conflict-free Smelter Program(CFSP). Smelter compliance is an important part of our supplier responsibility efforts to drive a conflict-free supply chain, meet our customer's requirements and comply with the recent United States Securities & Exchange Commission legislation requiring public companies to disclose information relating to the use of conflict minerals in their products.
Marvell expects a commitment from its supply chain partners to source responsibly, and as a downstream company, we will continue to communicate our expectations to our suppliers. We also encourage direct suppliers to adhere to our Supplier Code of Conduct and the Policy Statement, verify information regarding their Conflict Minerals policies and practices and the countries of origin of the Conflict Minerals they process.
In addition, we are asking our direct suppliers to encourage their supply chain partners, in particular the smelters, to obtain a conflict-free designation from an independent, third-party audit program. We support participation in programs like the CFSP and encourage sourcing from CFSP validated smelters. Marvell believes programs such as the CFSP has the capability and momentum to enable the industry to source 3TG minerals from validated conflict-free smelters. For those suppliers found to be sourcing from smelters that are not validated as conflict-free, we expect our direct suppliers to establish an alternative source of conflict minerals.
Engagement with the Conflict-free Sourcing Initiative
EICC and GeSI jointly developed the Conflict-Free Sourcing Initiative (CFSI) and Conflict-Free Smelter Program (CFSP) in 2008. CSFI’s flagship program, CFSP uses an independent third-party audit to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials. Companies can then use this information when making their sourcing decisions. The goal of this voluntary program is to facilitate sourcing of the conflict-free minerals. A list of smelters and refiners that meet the standards of the audit are published on CFSI's website.
As a member of the Conflict-Free Sourcing Initiative, Marvell participates in the activities of the CFSI, a leading industry program focused on conflict-free supply chains that helps manage risk by improving supply chain transparency on conflict minerals. Marvell participates in CFSI’s Due Diligence Sub-Team and Smelter Identification Working Groups, benchmarking its practices and teaming up with CFSI members to face the challenges of tracing the chain of custody of conflict minerals. Marvell also leverages CFSI’s reputable resources and compliance programs, and together the CFSI, views this as an opportunity to address responsible sourcing and play active role in a multi-stakeholder community.
Read more on CFSI