The Sherwin-Williams Company Conflict Minerals Policy:
The Sherwin-Williams Company takes very seriously the concerns that led to the enactment of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act regulating conflict minerals. This legislation was adopted to address various humanitarian injustices related to the mining of conflict minerals namely tin (cassiterite ore), tantalum (coltan ore), tungsten (wolframite), and gold sourced from the Democratic Republic of the Congo and the adjoining countries of Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. We are required to report annually to the Securities and Exchange Commission (SEC) on the source and chain of custody of the conflict minerals contained in our products. In August 2012, the SEC issued the final rules for reporting of tin, tungsten, tantalum and gold used in manufacturing of products.
The European Parliament and Council passed EU Regulation 2017/821 introducing supply chain due diligence obligations for EU importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas. Sherwin-Williams and its affiliated group companies do not import such minerals or metals to the EU as such, the mandatory supply chain due diligence requirements of the Regulation do not apply to Sherwin-Williams.
Sherwin-Williams will comply with these final rules by educating our suppliers regarding the importance of conflict free sourcing and by continuing to obtain information from our current suppliers concerning the origin of any conflict minerals that are used in the products.
Since we do not purchase these minerals directly from mines or smelters, we rely on our suppliers to report on the use of any of the named conflict minerals and identify the source and chain of custody of those conflict minerals. We will continue to work closely with our suppliers to ensure compliance and expect that our suppliers will conduct all their business dealings ethically and responsibly by recognizing international human rights concerns and following all applicable laws. As stated in our Supplier Code of Conduct, we expect our suppliers to provide suitable documentation verifying the source and chain of custody of conflict minerals contained in products sold/provided to us. Any supplier who is unable or unwilling to provide the requested information regarding conflict free sourcing will be subject to review and potential loss of future business.