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SEC Filings

SD
GRAHAM HOLDINGS CO filed this Form SD on 05/31/2017
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that contain tantalum are capacitors; Forney’s products that contain Tungsten are electrical materials such as resistors. Joyce’s products that contain gold and tin are electrical wiring, name plates, castings and covers; products that contain tantalum are screws and nuts. These products incorporate generic components obtained from other companies that contain tin, tantalum and gold. The Conflict Minerals in the generic components are necessary to the functionality of Forney’s and Joyce’s products. These generic components are purchased from manufacturers and distributors. Forney and Joyce do not purchase any Conflict Minerals directly from mines, smelters or refiners.
 
 
3.
Supply Chain Overview

Because neither Forney nor Joyce purchase 3TG directly from any mine, refiner or smelter, they are in a “downstream” position in the supply chain, that is, downstream in the supply chain from smelters to refiners to retailers. As such, Forney and Joyce rely on their direct suppliers and distributors to provide information on the origin of the 3TG contained in components supplied to them, including sources of 3TG that are supplied to them from lower tier suppliers.

3.1 Conflict Minerals Policy

Forney and Joyce adopted the following Conflict Minerals Policy that is available on Forney’s website at http://forneycorp.com/conflict-minerals-policy and on Joyce’s website at http://joycedayton.com/about-us/certifications:

Under the Dodd-Frank Act of 2010, public companies are required to disclose measures they have taken to identify the source of “conflict minerals” in the products they manufacture or contract to manufacture (the “Conflicts Minerals Rule”).  These “conflict minerals” are the source of financing for armed conflicts in the Democratic Republic of the Congo (the “DRC”) and adjoining countries. The Conflict Minerals Rule is intended to reduce a significant source of funding for armed groups that are committing human rights abuses in the DRC and adjoining countries.

“Conflict minerals” are four specific minerals and their derivatives: columbite-tantalite (the metal ore from which tantalum is extracted), casseriterite (the metal ore from which tin is extracted), wolframite (the metal ore from which tungsten is extracted), and gold.

We are committed to the responsible sourcing of “conflict minerals” throughout our supply chain for products that we manufacture that contain these minerals.  To that end, we are putting policies and systems in place to reduce the risk that the minerals used in any of our products originate from conflict mines in the DRC.  We are committed to strengthening our efforts to ensure that we refrain from, directly or indirectly, taking or supporting any action that contributes to the financing of armed groups that are committing human rights abuses in the DRC and other covered countries.