Conflict Minerals Policy




The Sherwin-Williams Company acknowledges the concerns that prompted 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.

Annual Reporting & Final Rules

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.

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.

The SEC’s final rules stipulate that Sherwin-Williams impress upon our suppliers the importance of conflict-free sourcing and obtain information from them regarding the origin of any conflict minerals used in the manufacturing of their products.

Supplier Expectations

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 their source and chain of custody. We will continue to work closely with our suppliers to ensure compliance and expect our suppliers to conduct their business ethically and responsibly by recognizing international human rights concerns and following all applicable laws.

As stated in our 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.

Access our latest Conflict Minerals Report below.