Lowe’s Companies, Inc. has adopted this Conflict Minerals Policy Statement in support of our commitment to responsibly sourcing products that our customers can be proud to use in their homes and to help reduce violence and human rights abuses in the Democratic Republic of the Congo (“DRC”). In 2010, the U.S. Securities and Exchange Commission (“SEC”) issued a “conflict minerals” rule as mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The rule requires publicly traded companies to disclose whether the products they manufacture or contract to manufacture contain columbite-tantalite (tantalum), cassiterite (tin), wolframite (tungsten), and gold (collectively, “3TG”), which have been sourced from non-certified mines in the DRC or adjoining countries (collectively, “Covered Countries”). Lowe’s has developed and implemented a reasonable and documented due diligence process, consistent with the Organization for Economic Cooperation and Development’s Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, to determine the use, source, and origin of 3TG in our global product portfolio, and specifically, whether any of them originated in the Covered Countries. For further information on the due diligence process, refer to the Form SD filed annually with the Securities and Exchange Commission.
Lowe’s does not directly purchase raw conflict materials for products we sell and is committed to complying with the reporting requirements under the conflict minerals rule and responsibly sourcing 3TG from certified mines or conflict-free smelters or refiners. Accordingly, Lowe’s requires our vendors of Lowe’s Private Brand products (e.g. Kobalt® tools, allen+roth® home décor products, etc.) to be committed to the responsible sourcing of materials and to fully cooperate with Lowe’s to comply with the conflict minerals rule. Private Brand Vendors shall not provide products to Lowe’s containing 3TG sourced from Covered Countries unless they are sourced from a certified mine or conflict-free smelter or refiner. Private Brand Vendors shall have programs in place that satisfy this requirement, and part of such programs shall include the following:
- Maintain records supporting obligation to provide products to Lowe’s without 3TG originating in Covered Countries unless the 3TG are sourced from a certified mine or a conflict-free smelter or refiner; and
- Complete Lowe’s annual 3TG survey and additional questions related to the inclusion of 3TG in their products.
Lowe’s will evaluate its relationships with Private Brand Vendors on an ongoing basis to ensure continued compliance with this policy and may request traceability documentation regarding the source of any 3TG included in its Private Brand Vendors’ products. Lowe’s will consider to what extent its Private Brand Vendors comply with this policy in determining future business decisions.
Violations of Lowe’s policies, including the Conflict Minerals Policy Statement, can be reported through one of the following means:
- E-mail: firstname.lastname@example.org
- Telephone: 1-800-309-5859
- NAVEX Global:
- Website (option to report anonymously): ethicspoint.com
- Telephone: 800-784-9592 for the U.S. and Canada; 10-800-120-1239 for Southern China; 10-800-712-1239 for Northern China; 800-964214 for Hong Kong; 001-8008407907 or 001-866-737-6850 for Mexico; 00801-13-7956 for Taiwan; 1-800-80-8641 for Malaysia; 001-803-011-3570 or 007-803-011-0160 for Indonesia; 120-11067 for Vietnam; 001-800-12-0665204 for Thailand; 000-800-100-1071 or 000-800-001-6112 for India; 01800-9-155860 for Colombia; 0800-8911667 for Brazil or 503-619-1883 for use internationally