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The Gund Company is a privately-owned entity and therefore exempt from  Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (2010). However, we are committed to the responsible global sourcing of minerals worldwide which seeks practical solutions to curb the violence associated with trade in conflict minerals and to respect basic human rights.

We promote the observance of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Suppliers are expected to supply materials to The Gund Company that are “DRC conflict free.” “DRC conflict-free” means (1) any “conflict minerals”, columbitetantalite (coltan), cassiterite, gold, wolframite, or their derivatives, tin, tantalum, or tungsten (collectively the “3TGs”) necessary to the functionality or production of supplied materials which do not directly or indirectly finance armed groups through mining or mineral trading in the Democratic Republic of Congo or an adjoining country, or (2) any 3TGs in supplied materials that are from recycled or scrap sources.

Suppliers are expected to adopt policies and management systems with respect to conflict minerals and to require their suppliers to adopt similar policies and systems.

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