R.G. Barry Corporation and Subsidiaries

Conflict Minerals Policy


The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 requires publically traded companies to assert reasonable due diligence within their supply chain to determine if “Conflict Minerals”, defined as tin, tantalum, tungsten and gold (3TG), used in their products are being sourced from mines controlled by non-government or unlawful military groups within the Conflict Region.  The “Conflict Region” is defined as the Democratic Republic of the Congo (DRC) and surrounding countries.   

The due diligence process of tracing materials back to their mine of origin is a complex endeavor.  Due to this complexity, the R.G. Barry Corporation has engaged a third party with expertise in this area of supply chain compliance.  Our commitment includes:

  • Developing policies and processes to prevent the use conflict minerals within our products that are mined from the Conflict Region.
  • Not knowingly procure conflict minerals that from facilities in the Conflict Region that are not certified as conflict
  • Requesting suppliers whose products contain conflict minerals to complete a the RG BARRY Conflict Mineral Survey and assist in establishing policies, due diligence frameworks, and management systems consistent with the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains Minerals from Conflict- Affected and High Risk-Areas that are designed to accomplish this goal, and requiring their suppliers to do the same.

The R.G. Barry Corporation strives to establish and maintaining long-term relationships with suppliers.  However, if we determine that any supplier is, or a reasonable risk exists that it may be, violating this policy, we will require the supplier to commit to corrective action to move to a conflict free source.  If corrective action is not taken, we will look to alternative sources for the product.  If it is determined that any of the components of our products contain minerals from a mine or facility that is “non-conflict free”, we will strive to transition to products that are “conflict free”.