As a publically traded company based in the U.S., Lear is required to comply with the requirements of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the U.S. Securities and Exchange Commission (SEC) rules and regulations. Lear must perform due diligence on, and make disclosures concerning its use of conflict minerals originating in the Democratic Republic of the Congo and adjoining countries.
All Lear suppliers are required to respond to information requests from Lear regarding the uses and sources of conflict minerals (tin, tungsten, tantalum and gold) in their products including information about minerals that are recycled or scrap.
In order to respond to Lear's information requests, suppliers will need to make similar inquiries of their suppliers as a means to investigate the source of materials in their products, and to provide Lear the requested information based upon the results of such inquiries.
Lear may be required, and may require its suppliers, to perform due diligence on the source and chain of custody of its conflict minerals in accordance with the "OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas." In addition, suppliers may be required to make certain representations/certifications with respect to the use of conflict minerals.