Conflict Minerals Sourcing

Background on Section 1502 of the Dodd-Frank Act


Pursuant to Section 1502 of the Dodd-Frank Act Wall Street Reform and Consumer Protection Act, which was adopted by the U.S. Securities and Exchange Commission (the “SEC”) on August 22, 2012, all entities that file with the SEC are required to disclose annually whether they manufacture or contract to manufacture “any conflict minerals that are necessary to the functionality or production” of their products. Conflict minerals include columbite-tantalite (coltan), cassiterite, gold or wolframite, or their derivatives tantalum, tin and tungsten, regardless of where they are sourced, processed or sold. The intent of this legislation is to further the goal of eradicating the use of conflict minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or any adjoining country.


Our Policy


Conflict minerals originating from the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”) are sometimes mined and sold, under the control of armed groups, to finance conflict characterized by extreme levels of violence. Some of these minerals can make their way into the supply chains of products used around the world. Activision Blizzard’s suppliers acquire and use conflict minerals from multiple sources worldwide. As part of our commitment to corporate responsibility and respecting human rights in our own operations and in our global supply chain, it is our goal to use tantalum, tin, tungsten and gold in our products that do not directly or indirectly finance or benefit armed groups in the Covered Countries, while continuing to support responsible mineral sourcing in the region.


We encourage our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us do not contain conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries. We also require our suppliers to comply with our Vendor Code of Conduct and to conduct their business in alignment with our supply chain responsibility expectations.


In support of this policy, Activision Blizzard will:


  • Exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and encourage our suppliers to do likewise with their suppliers;
  • Provide, and expect our suppliers to cooperate in providing, due diligence information to determine whether the tantalum, tin, tungsten and gold in our supply chain do not directly or indirectly finance or benefit armed groups in the Covered Countries; and
  • Commit to transparency in the implementation of this policy by making available reports on our progress to relevant stakeholders and the public.

The terms “Activision Blizzard,” “we,” “our,” and “us” are used herein to refer collectively to Activision Blizzard, Inc. and its subsidiaries.


Grievance Mechanism and Reporting


Reports of any actual or potential violation of this policy, including any potentially unlawful or unethical situation, or any other related concerns may be reported to Activision Blizzard at vendorcompliance@activisionblizzard.com.


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