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January 9, 2015
To Whom It May Concern:
With the passage in 2010 of the Doddâ€Frank Wall Street Reform and Consumer
Protection Act, publicly traded companies must determine whether certain minerals
that are necessary to the functionality or production of their products originated in
the Democratic Republic of the Congo or any adjoining African country. The
legislation further requires these companies whose products contain metals derived
from tantalum, tin, tungsten and gold to report annually to the U.S. Securities and
Exchange Commission (SEC) disclosing whether those minerals originated in the
African countries. If so, then the company must disclose to the SEC measures they
took to exercise due diligence on the source and chain of custody of the minerals.
It is our understanding that this legislation is not a call for a boycott or ban on the use
of minerals from Congo but a means to demand greater transparency in the supply
chain and a call for companies to undertake the due diligence required to ensure they
are not contributing to the conflict.
TMG, as a private company is not subject to the requirements of this
Act. We support the legislation’s efforts to reduce the resources and supply chains to
the armed groups and military units bringing violence and undue suffering against
the people of the Congo, and we take every step at our disposal to ensure that our
products are manufactured in a legal, responsible manner. We are unaware of any of
our suppliers' products having its mineral source from that region but we cannot with certainty
say where the raw minerals might originate from.
While we acknowledge that many customers or their end users may be public
companies, subject to the disclosure requirements of this Act, we are not able to
determine the original source of minerals that might be used in the manufacture of
our products.