Section 1 – Conflict Minerals Disclosure
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Item 1.01
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Conflict Minerals Disclosure and Report
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Background
In 2010, the
Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”) became law. Section 1502 of the Act required the Securities and Exchange Commission (the “SEC”) to promulgate rules to provide a framework under which
U.S. publicly-traded companies would be required to make certain disclosures about the presence and source of certain minerals in their products. Specifically, the Act was designed to provide transparency as to which companies were sourcing
materials from the Democratic Republic of the Congo (the “DRC”) or adjoining nations, a region known for human rights concerns in connection with mining activities. The minerals mentioned in the Act are now commonly known as
“3TG”: tin, tantalum, tungsten and gold.
Belden Inc. (the “Company”) is a manufacturer of certain products in which
one or more of the 3TG minerals is present and is necessary to the functionality of the products. For example, the Company manufactures a wide variety of cable products in which the conductor is
tin-plated
copper, the Company manufactures connectors utilized in signal transmission that are gold plated, and the Company manufactures networking equipment containing printed circuit boards that contain tungsten and tantalum.
Once the SEC issued final rules (the “Rules”) implementing Section 1502 of the Act in the fall of 2012, the Company formed a
conflict minerals steering committee composed of representation from the following functional areas of the Company: purchasing, legal, engineering, information technology, finance, operations, environmental, health and safety, sales and marketing,
and internal audit. Following a series of meetings, interviews and training sessions, the steering committee delegated to the regional purchasing directors (Americas, EMEA and Asia-Pacific) the task of conducting the reasonable country of origin
inquiry required by the Rules.
Reasonable Country of Origin Inquiry
Like many other U.S. manufacturers, the Company sources its 3TG raw materials and components containing 3TG through a complicated, many layered
supply chain oftentimes involving many parties with which the Company has no business relationship and no privity of contract. It quickly became apparent that determining whether or not any of this 3TG originated in the DRC was going to be a
challenging task requiring an extensive due diligence process. Because the Company has been unable to make any definitive determination of the country of origin of its 3TG materials without such due diligence, it believes it is required to prepare
the Conflict Minerals Report described in the Rules. The Company’s Conflict Minerals Report is included as
Exhibit 1.01
to this Form SD and is hereby incorporated by this reference and is available on the Company’s website at
www.belden.com
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As described in Item 1.01, the Company’s Conflict Minerals Report is included as
Exhibit 1.01
to this Form SD.
Section 2 – Exhibits
The following exhibit is filed as part of this report:
Exhibit 1.01 – Conflict Minerals Report of Belden Inc. for the calendar year ending December 31, 2018
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