February 28th, 2016

Company Conflict Minerals Policy Statement


Sustainable conduct forms the basis of our business decisions and dealings with our stakeholders. Adherence to applicable laws, recommended guidelines and internal policies is an essential part of our integrity, and will forever remain fundamental to our business.

In order to also ensure Sustainability in our Supply Chain, we have established the “Code of Conduct”. It is based on – among others, the UN Global Compact, of which the Chambers Federation is a signatory member. We contractually commit our cooperative suppliers to the “Code of Conduct for Chambers Federation Suppliers” and expect them to promote these standards to their members.

Chambers Federation is not listed on any U.S. stock exchange and thus not under an obligation to respond to the SEC requirements published in August 2012 and to issue a Conflict Minerals Report. Nevertheless, Chambers Federation continues to exercise its self-appointed duty of care within the supply chain. Chambers Federation, like many other companies, is aware of the difficult situation that products and components purchased from suppliers may contain minerals originating from conflict-affected countries.

We have rolled out a uniform and enterprise-wide process and software to determine the use, source and origin of Conflict Minerals in our supply chain. We work closely with our cooperative suppliers to support us in carrying out these steps. Where necessary, we work with our cooperative suppliers in order to remediate risks and perform additional due diligence so that we can continue to source responsibly, building on established management processes.

We do not, however, encourage implementing a de facto embargo on the DRC and adjoining countries in the sourcing of Conflict Minerals. We in fact encourage the aggressive, responsible sourcing of minerals from this region to promote peace and economic stability and therefore eliminating the “conflict” from “conflict minerals”. This is in line with our duty to comply with the principles of non-discrimination with regard to supplier selection and treatment and follows the call of several internationally active human rights organizations.

Chambers Federation actively supports and plans to further support the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” as an indirect advisor for the development of the respective Due Diligence processes which expressly recognizes a Risk-Based Due Diligence in the Mineral Supply Chain.


Thank you

Matthew Chambers

President, Chambers Federation

Chambers Financial Group, subsidiary, a US Federal Contractor