Conflict materials

The United States Dodd-Frank Act (Section 1502) of 2014 sought to prevent the financing of armed groups in certain conflict regions via raw material trading. Companies trading on the US stock exchange were required to provide information to the stock exchange regarding the possible inclusion of so-called “conflict materials” in their products. This in turn led to the requirement for suppliers to likewise provide details of the sources of raw materials. The trickle-down effect meant that indirect German suppliers were also required to evidence compliance where they were active as suppliers to
the US market, or were acting as intermediaries.

A similar provision has applied within the European Union since 2017: the (EU)2017/821 Directive. A duty of care across the supply chain meant that importers of Tin, Tantalum, Tungsten and Gold had to fulfil self-certification requirements for all transactions with crisis regions.

PFARR Stanztechnik is neither directly subject to the Dodd-Frank Act nor classed as an EU importer in the sense of EU Directive 2017/821. Nevertheless, having regard to our corporate and ethical responsibilities, we embrace the regulations fully. We have a documentary process in place recording the origins of all the materials we deploy.

We require written confirmation from all our suppliers that no conflict materials are delivered to us as set out in the Dodd-Frank Act (Sect. 1502) or the EU Directive (EU)2017/821. This guarantee is an absolute prerequisite to supplying raw materials to PFARR Stanztechnik.

German Chamber of Commerce notes on the Dodd-Frank Act (Section 1502) (EN)