Harley-Davidson to monitor supply chain for Conflict Minerals

Publish Date: 
Jun 20, 2013

MILWAUKEE, Wis. - Harley-Davidson today issued a statement confirming its commitment to monitor materials that may be sourced from countries where armed conflict and human rights abuses have been identified.

"...we expect our suppliers to perform similar due diligence on the sources of Conflict Minerals in their respective supply chains and make their findings available to us."

Harley-Davidson statement

Under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, and related U.S. Securities and Exchange Commission rules and regulations, certain public companies must perform supply chain due diligence to identify the extent to which their products contain Conflict Minerals originating from the Democratic Republic of Congo and certain adjoining countries (called "Covered Countries").

Conflict Minerals include gold, tantalum (columbite-tantalite or coltan), tin (cassiterite) and tungsten (wolframite) sourced from the "Covered Countries" of Angola, Burundi, Central African Republic, Congo Republic, Rwanda, Sudan, Tanzania, Uganda and Zambia.

"Harley-Davidson is committed to supporting responsible sourcing of its minerals from suppliers that share our values around human rights and environmental responsibility. To further this objective, we are committed to complying with the requirements set forth in the final rule," the OEM stated.

The Motor Co., in its statement, said it will:

  • Support the objectives of the legislation on Conflict Minerals;
  • Perform supply chain due diligence in accordance with the Organization for Economic Cooperation and Development’s internationally recognized and established due diligence framework;
  • Identify the presence of Conflict Minerals in the Harley-Davidson supply chain that are or may be necessary to the functionality of the company's products;
  • Develop repeatable processes to determine whether Conflict Minerals in its supply chain, if any, originate from Covered Countries or are derived from recycled or scrap sources;
  • Perform supplier inquiries to ensure the responsible sourcing of minerals within the Harley-Davidson supply chain;
  • Educate suppliers with respect to the SEC reporting requirements related to Conflict Minerals;
  • Require all Harley-Davidson suppliers to adhere to the company's Supplier Code of Conduct, which includes the responsible sourcing of materials; and
  • Prepare an appropriate disclosure for Harley-Davidson’s required SEC filings on the due diligence performed.
"In addition to the foregoing commitments, we expect our suppliers to perform similar due diligence on the sources of Conflict Minerals in their respective supply chains and make their findings available to us," the OEM stated.
 
Posted by Mary Slepicka