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SD
GRAHAM HOLDINGS CO filed this Form SD on 05/31/2017
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conclusively determine the identity of all of the smelters from which their suppliers source 3TG or the countries of origin of 3TG in their products.
 
 
7.
Steps to Mitigate Risk and Improve Due Diligence

The Company is working to strengthen its commitment to the responsible sourcing of conflict minerals. Forney and Joyce will continue to include in new purchase orders or contracts, specific language that requires suppliers to cooperate with them by providing information about the supplier’s source of Conflict Minerals and smelters. In addition, they will continue working with suppliers to obtain 3TG sourcing information and will strengthen their procedures to engage with manufacturers and distributors to obtain accurate and complete information about their supply chains. Cooperation with respect to sourcing by suppliers will be a factor in allocating future purchases. Forney and Joyce will work with suppliers as needed to better communicate the requirements of the Conflicts Mineral Rule.