Dell’s Position on SEC Conflict Minerals Ruling

The Democratic Republic of the Congo has been mired in a brutal conflict since 1998; the resulting hostilities and human rights abuses are largely fueled by the trade of “conflict minerals” including gold, tantalum, tin and tungsten. As a manufacturer of products that contain these materials, Dell is committed to operating in a socially responsible way.

 Today the U.S. Securities and Exchange Commission released its conflict minerals reporting standard, delivering the Final Rule for Dodd-Frank section 1502. We appreciate the hard work and dedication of everyone involved in the process. Over the coming weeks, we will be evaluating the rule for impacts to our business and suppliers, making adjustments as necessary to prepare us for the upcoming disclosure requirements.

In the interim, I want to be clear that Dell's policy is to refrain from purchasing from any known conflict sources — and we expect that our suppliers adhere to the same standards. We have notified all our suppliers of our policy on conflict minerals and have asked each supplier to provide us a confirmation of their conflict-free status. Dell also works diligently to educate suppliers, investors and customers on this issue through speaking engagements, workshops and stakeholder engagements.

More specifically, we’re engaged with the Electronics Industry Citizenship Coalition (EICC), an organization devoted to improving social and environmental conditions in electronics supply chains, to develop a process that companies can use to track the origin of these minerals — regardless of the industry in which they will be used. In 2011, the EICC launched the world’s first conflict-free smelter program, which tracks documentation from the smelter back to the mine of origin.

Long ago we started our journey to enable responsible sourcing through our complex supply chain. We have been building internal processes in anticipation of the new requirements. We are committed to working proactively with other industries, the government and non-governmental organizations to reach an agreement on a solution to purchase conflict-free minerals and to help implement this solution. Dell will continue to participate in the industry conversation, and we encourage every producer using these minerals to join us.

To learn more about our history on this issue, I invite you to visit www.dell.com/extractives

About the Author: Susie Allen