Conflict Minerals Policy
FMC Corporation has implemented a conflicts minerals program and incorporated it into our overall corporate compliance program. Throughout this report, “FMC”, “we”, “us” or “our” means FMC Corporation and its consolidated subsidiaries.
As part of that program, in October 2013 we adopted the following policy with respect to conflict minerals.
FMC Corporation and its subsidiaries (“FMC”) are committed to sourcing components and materials from companies that share our values regarding respect for human rights, integrity and environmental responsibility.
FMC is committed to complying with Section 1502 of the Dodd-Frank Act, which aims to prevent the use of minerals containing tin, tantalum, tungsten and gold (3TGs) that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (DRC) or in adjoining countries (“conflict minerals”).
Suppliers to FMC are required to commit to being or becoming “conflict-free” (which means that such supplier does not source conflict minerals) and to sourcing 3TGs only from conflict-free smelters. Each supplier to FMC that is providing necessary 3TGs is required to provide completed EICC-GeSI Conflict Minerals Reporting Templates evidencing such supplier’s commitment to becoming conflict-free and documenting countries of origin for the 3TGs that it supplies.
At the time of the writing of this Conflict Minerals Statement, the term “Conflict mineral” includes Columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten. As used in this Conflict Minerals Statement, the term “3TG” includes tin, tantalum, tungsten and gold.
Prior to the sale of the FMC Peroxygens segment to a third party in February 2014, FMC Peroxygens manufactured peroxygens chemicals, including hydrogen peroxide, peracetic acid and persulfates, for a variety of applications, and silicates as well as other materials for environmental remediation applications. Certain hydrogen peroxide products sold by the FMC Peroxygens segment included stannate (i.e. tin-containing) chemicals as stabilizers. At the time of its sale, FMC Peroxygens was the only FMC business segment that used 3TGs in products that it manufactured.
In April 2015, we acquired Cheminova A/S, a Denmark Aktieselskab ("Cheminova"), which has been integrated into our Agricultural Solutions segment. We have undertaken a thorough examination of all materials used in the manufacture of Cheminova’s products. Other than sodium tungstate, which is used as a catalyst in one our plants and therefore not covered by the conflict minerals legislation, no other 3TGs are included in any of Cheminova’s products.
During the year ended December 31, 2015, aside from the above-noted use of sodium tungstate, FMC did not include any 3TGs in any products manufactured by FMC or its subsidiaries. As a result, at this time, we are no longer required to file any further Forms SD with the Securities and Exchange Commission (“SEC”).
FMC continually monitors the materials used in the manufacture of its products, including whether any such materials include 3TGs. Although we currently have no plans to use 3TGs in the manufacture of our products other than the use of sodium tungstate as a catalyst noted above, if and when we do so, we will once again file a Form SD and, if applicable, an associated Conflict Minerals Report with the SEC as required by applicable SEC rules in effect at that time.
1This definition may be expanded in the future to the extent that the U.S. Secretary of State determines that there exist any other material or its derivatives that are financing conflict in the Democratic Republic of the Congo or an adjoining country.