The Securities and Exchange Commission (“SEC”) adopted final rules in August 2012 regarding disclosure and reporting requirements with respect to the use of “conflict minerals” to implement Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). The rules require public companies such as Schlumberger to perform supply chain due diligence and disclose annually whether certain products they manufacture or contract to manufacture contain conflict minerals originating from the “covered countries” that are necessary to the functionality or production of those products.
Definitions. The term “covered countries” means the Democratic Republic of the Congo (the “DRC”) and its adjoining countries. “Conflict minerals” means tin (cassiterite), tungsten (wolframite), tantalum (columbite-tantalite or coltan), gold or their derivatives, which originate in the covered countries.
Schlumberger recognizes that there are serious human rights abuses associated with the extraction, transportation and trade in minerals in the covered countries. We have always supported responsible sourcing of materials from suppliers that share our values and we commit to avoid contributing to the conflict through our sourcing activity.
As expressed in our code of conduct (our “Blue Print in Action”), Schlumberger does not tolerate any corruption of any kind in dealings with its suppliers, and we expect our suppliers to adhere to the same standard. We work with our suppliers in a socially responsible and ethical manner. A potential supplier is selected and retained only after it has evidenced in writing its adherence to our code of conduct and other internal compliance requirements, including health and safety, and environmental. In addition, we audit our top suppliers every two years to ensure adherence to our code of conduct. We have developed this conflict minerals policy to supplement our code of conduct.
Schlumberger is committed to purchase only those parts and products containing minerals that have been procured through a validated conflict-free supply chain, so as to avoid the use of minerals that have financed conflict in the covered countries, and we expect our suppliers to abide by the same standard.
Schlumberger is taking a variety of actions designed to assist in compliance with the conflict minerals rules. For example:
This Policy will be reviewed periodically to ensure ongoing suitability, and is in addition to our suppliers’ basic obligations to comply with Schlumberger standards.