Dodd-Frank Act Statement Statement of VITLAB GmbH concerning the use of “conflict minerals”

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On August 22, 2012, the U.S. Securities and Exchange Commission adopted final rules to implement reporting and disclosure requirements related to "conflict minerals", as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) of 2010.


Companies registered on the U.S. stock exchange are required to report annually whether the products they manufacture or contract to manufacture contain conflict minerals that are necessary to the functionality or production of those products.


The intent of these regulations is to curtail the trade with conflict minerals, which originate from the Democratic Republic of the Congo (DRC) or surrounding countries and finance or benefit the ongoing violent conflict in the DRC or an adjoining country.


Conflict minerals within the meaning of the Dodd-Frank Act (status as of 01.01.2013) are: 

  • columbite-tantalite (coltan)
  • cassiterite (tin)
  • wolframite (tungsten)
  • gold
  • and their derivatives
VITLAB as a company is not subject to the mentioned reporting and disclosure requirements.


In light of the requirements of the Dodd-Frank Act we are working with our suppliers to trace material components in our products in order to determine whether minerals originating from mining or noncertified smelting operations in the conflict region are used in our products. We will not knowingly use conflict minerals from noncertified smelters of the conflict region in our products. As a result, we are requiring our suppliers to trace material components in the products they supply to us down to a conflict free certified smelter and to provide us with documentation regarding their due diligence efforts. We are requiring our suppliers to procure components, parts, or products containing conflict minerals that have been identified to be conflict-free.


Supply chains and the routes by which these conflict minerals are traded and sold are very complex.


All potentially affected suppliers responded to our request concerning conflict minerals. Currently there is no information that conflict minerals originating from the countries concerned might be used in our products.


Please feel free to contact us should you have any further questions (


Grossostheim, March 3rd, 2020