Williams-Sonoma, Inc. (“WSI”) is committed to corporate responsibility and sustainable practices. As part of that commitment, WSI is ensuring that metals and other minerals contained in our products are obtained, produced and used in an environmentally and socially responsible manner. As such, we are working to implement and ensure full compliance with section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that was signed into law in 2010 relating to trade in conflict minerals.
The conflict-minerals provision of the Dodd-Frank Act is intended to address the situation in the mining industry in parts of the Democratic Republic of Congo (DRC) and neighboring countries in Africa, where warlords controlling local mines engage in deplorable human-rights abuses and use mining proceeds to fund regional conflicts. The law calls upon companies to provide information to the Securities and Exchange Commission (SEC) regarding whether the subject minerals (and their derivatives) – cassiterite, columbite-tantalite (coltan), gold, and wolframite, which are commonly referred to as “3TGs” and are used for the manufacture of certain products – originate from conflict mines in the DRC or neighboring countries. The conflict minerals provision applies to 3TGs that are necessary to the functionality or production of products that are manufactured or contracted to manufacture.
ENFORCEMENT AND MONITORING OF COMPLIANCE WITH THIS POLICY
To ensure compliance with section 1502 of the Dodd-Frank Act and to remain committed to our corporate responsibility goals, we are putting in place several practices that were developed by the Organization for Economic Cooperation and Development (OECD) and endorsed by the U.S. Department of State to incorporate proper due diligence measures into our supply chain regarding trade in conflict minerals. These practices provide guidance for responsible sourcing and the procurement and use of 3TGs from conflict-free mines:
- Establish strong company management systems;
- Identify and assess risk in the supply chain;
- Design and implement a strategy to respond to identified risks;
- Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain; and
- Report on supply chain due diligence.
WSI will work to identify and eliminate the use of and sourcing of conflict minerals in its supply chain. Additionally, we will need the full cooperation of our supply chain business partners in order to meet our compliance goals. This involves communicating our Conflict Minerals Law Compliance Policy to our supply chain partners and asking them to provide us with verifiable evidence that the procurement and use of 3TGs from conflict-free mines is being carried out.
We take our commitment to our corporate responsibility goals and our compliance with conflict minerals law very seriously. As such, we will undertake every effort possible to ensure full compliance. All information we provide to the SEC in compliance with the conflict-minerals law will be available to the public through our website. Additionally, WSI intends to strengthen its due diligence program as additional tools become available, and review & update its policy as necessary.