In 2015, ITW filed its second conflict minerals disclosure, per U.S. Securities and Exchange Commission (SEC) requirements. While the company has a strong foundational reporting framework in place, we practice continuous improvement on this framework.
Refining our process
Working closely with our individual businesses and affected suppliers, for obtaining necessary declarations from those suppliers whose products contain tin, tantalum, tungsten or gold – which are considered conflict minerals under the SEC rule. As part of this commitment, ITW recently conducted a voluntary internal and external analysis of its entire reporting process and is analyzing the results to identify areas to improve further.
In addition, ITW continues to:
- Follow the internationally accepted Organization for Economic Co-operation and Development (OECD) guidelines, as it applies to conflict minerals.
- Oversee overall compliance with the disclosure requirement via a cross-functional internal committee, with members from legal, audit, information technology, strategic sourcing, and environment, health, safety and sustainability.
- Ensure implementation of its Conflict Minerals Policy Statement, which the company reviews on a regular basis to identify opportunities to strengthen it.
Meeting disclosure requirements calls for collaboration
At ITW, gathering the necessary information to complete the conflict minerals disclosure requires significant collaboration internally and externally. The conflict minerals program manager partners with sourcing professionals within each of ITW’s seven business segments, as well as other primary contacts assigned to ITW’s manufacturing locations.
Sourcing analyst for Polymers & Fluids
"Through collaborations with other sourcing analysts and the corporate sourcing team, we’ve developed a streamlined approach that helps the primary contacts at our businesses understand what needs to be done to comply with conflict minerals regulations. At the segment level, our understanding of the requirements and ITW’s process has allowed us to provide further clarification to our businesses with respect to their products and whether their items contain conflict minerals. The end result is increased accuracy of the information we are gathering."
Recognition for ITW’s progress
While we seek continuous improvement in our conflict minerals reporting process, ITW is pleased with recognition we received in 2015 from three third-party studies examining the quality and effectiveness of conflict minerals disclosures.
- Responsible Sourcing Network’s 2015 report, Mining the Disclosures, rated ITW’s conflict minerals response as Good, and the company had the second-highest rating in the machinery industry.
- Assent Compliance’s 2015 Conflict Mineral Benchmarking Study gave ITW a high score for both compliance and on its “good practice” measure.
- Development International’s Conflict Mineral Disclosure Scorecard recognized ITW with a score of 100% for reporting year 2014.