Jabil Responsible Minerals Policy

Responsible Minerals Sourcing Policy

The United Nations has found that the trade of certain rare earth minerals is helping to finance the civil conflict in the Democratic Republic of the Congo (DRC), characterized by extreme levels of violence. These minerals are commonly referred to as “3TG” (tin, tantalum, tungsten, & gold).

In recognition of this issue, in July 2010, the U.S. government enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act. Section 1502 of the Dodd-Frank Act was intended to provide a means for starving armed groups in the Congo region of funding used to finance the civil conflict described by the United Nations. In August 2012, as required by Section 1502 of the Dodd-Frank Act, the U.S. Securities and Exchange Commission adopted Rule 13p-1 under the Securities Exchange Act, which requires all public companies to publicly report on an annual basis certain information concerning 3TG contained in products that they manufacture or contract to manufacture to the extent that 3TG is necessary to the functionality or production of the products.

Jabil fully supports this legislation and is committed to responsible sourcing of 3TG as well as full compliance with the requirements of the Rule. Furthermore, as a founding member of the Responsible Business Alliance (RBA), formerly known as the Electronic Industry Citizenship Coalition (EICC), Jabil embraces the industry coalition's due diligence and reporting processes that seek to ensure supply chain transparency by obtaining 3TG country of and other origin information from all suppliers directly managed or sourced by Jabil.

Jabil does not directly source 3TG from mines, smelters or refiners, and is in most cases several or more levels removed from these market participants. Jabil, therefore, expects all suppliers to assist us in complying with the Rule, by declaring any components, parts, and products that contain 3TG and further providing associated country of and other origin information. In addition, Jabil expects our suppliers to implement controls on their supply chains consistent with Jabil's responsible sourcing commitment, so that they are able to provide us with this information and so that all of the 3TG in the components, parts, and products that we purchase from them is "conflict free”. Suppliers who supply components, parts or products containing 3TG are expected to source those minerals from ethically and socially responsible sources that do not directly or indirectly contribute to conflict.

Without limiting the foregoing, suppliers are expected to, directly and indirectly, source 3TG only from sources that do not directly or indirectly benefit or finance armed groups in the DRC or another covered country, in each case within the meaning of the Rule. Among other things, we expect our suppliers to, where possible, source 3TG from smelters and refiners that are validated as being conflict free and otherwise implement, and require their direct and indirect suppliers to implement, policies, protocols, standards, systems, frameworks and procedures that are consistent with the Rule and the framework for Organization for Economic Co-operation and Development's Due Diligence (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs) including the ANNEX II. Suppliers who do not comply with these expectations will be reviewed and evaluated accordingly for future business and sourcing decisions.

Suppliers will continue to be required to comply with complementary policies of Jabil, including those relating to corruption, money-laundering and bribery.

Other due diligence initiative
Cobalt is not currently a regulated “conflict mineral” or subject to existing mandatory due diligence requirements. Jabil is aware that this mineral is increasingly associated with severe human rights violations (such as child labor) and shall continue to monitor for regulatory and other developments regarding cobalt.

We have mechanisms for employees, suppliers, and other interested parties to report violations of our Conflict Minerals Policy. The global compliance hotline number is 1-877-217-6328 and the Conflict Minerals inquiry email address is: conflict_minerals@jabil.com