Dodd-Frank Act

Section 1502 of the Wall Street Reform and Consumer Protection Act, known as the Dodd-Frank Act, directs the Securities and Exchange Commission (SEC) to impose reporting requirements on publicly-traded companies whose products contain  conflict minerals  which are defined as tantalum, tin, tungsten and gold.

Specifically, the Dodd-Frank Act requires publicly-traded companies to disclose their use of conflict minerals originating from the Democratic Republic of the Congo (DRC) and adjoining countries that are  necessary to the functionality or production  of a product. Mining and transportation of conflict minerals is a significant source of funding for armed groups that fuel conflict and commit human rights abuses in the DRC.

Section 1502 was enacted to address these humanitarian concerns and reduce this source of funding for the armed groups in this region.

ATI Policy

ATI is committed to full compliance with the Dodd-Frank Act. ATI's policy is to only purchase materials from legitimate and reputable suppliers, and to maintain a sustainable and responsible supply chain that does not in any way contribute to human rights abuses, fuel conflict, or benefit illegal armed groups.

In accordance with this policy, ATI has implemented internal risk-based due diligence procedures designed to provide transparency to the origin of conflict minerals in our supply chain in compliance with the Dodd-Frank Act. ATI will communicate as appropriate with its suppliers regarding these procedures.

ATI expects all of its suppliers to conduct business in a manner that respects human rights and not to support sources or parties that contribute to human rights abuses. ATI expects its suppliers to be aware of the requirements of the Dodd-Frank Act, and to fully support ATI's Dodd-Frank Act compliance efforts by providing transparency into the supply chain from the original source to ATI.