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On 05 August 2024, Ethical Consumer viewed the Amazon.com Inc website for information on its approach to conflict minerals. The following documents were consulted: 2022 Form SD, 2023 Sustainability Report.

Conflict minerals are minerals mined in conditions of armed conflict and human rights abuses, notably in the eastern provinces of the Democratic Republic of Congo (DRC). The key minerals in question are Tantalum, Tin, Tungsten and Gold (3TG for short) and are key components of electronic devices, from mobile phones to televisions.

Ethical Consumer expected all companies manufacturing electronics to have a policy on the sourcing of conflict minerals. This policy should articulate the company's commitment to conflict-free sourcing of 3TG minerals, from the DRC region, and include details of due diligence on the issue.

Ethical Consumer also looks for:
- Commitment to minimising the environmental impacts of mining and details of due diligence steps on this.
- Action or plans to address other high impact minerals like cobalt and lithium
- That conflict minerals expectations are included in supplier contracts and suppliers are required to only use audited smelters
- That the company publishes a list of smelters and refiners used
- Whether the company is increasing use of recycled conflict minerals and has done due diligence on their sources
- Any third-party criticisms of the company in relation to conflict minerals.

The company's policy outlined its commitment to conflict-free sourcing from the DRC region: "We are committed to avoiding the use of minerals that have fueled conflict, and we expect our suppliers to support our efforts to identify the origin of gold, tin, tungsten, and tantalum used in products that we manufacture or contract to manufacture.” It also stated that it was sourcing from the covered countries, including the DRC.
(10 points)

The company did not appear to acknowledge the issue of environmental destruction caused by mining or have a commitment to minimising it.

The company already addresses or has immediate plans to address at least one and up to four other high impact minerals. The most common ones are cobalt, copper, lead, nickel, zinc, mica and lithium. It discussed due diligence processes for cobalt.
(10 points)

The company detailed the steps it takes to identify, assess, mitigate and respond to conflict risks within its supply chain. It stated: “we designed our due diligence on the source and chain of custody of the gold, tin, tungsten, and tantalum in our in-scope products in accordance with the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Third Edition, and the related Supplements on Tin, Tantalum and Tungsten and on Gold”. It then outlined three steps for its due diligence process.
(20 points)

The company did not detail the steps it takes to identify, assess, mitigate and respond to environmental risks within its mineral supply chain. (0 points)

It was not clear that the conflict minerals policy was included in supplier contracts and / or agreements. It stated that this was the case in its policy, "Our policy is reflected in our Supply Chain Standards, available
at https://sustainability.aboutamazon.com/social-responsibility#section-na…, which we communicate to our suppliers through our supplier screening process, contracts with suppliers, or by sending our suppliers a copy of the Supplier Code". Its supplier manuals and codes were searched and nothing was found on conflict minerals.

The company did not appear to have a commitment that its supply chain would only use 3TG minerals from smelters that have been audited and verified as conflict free by the Responsible Mineral Assurance Process, as they become available. it stated "We strive to have 100% of tin, tungsten, tantalum, and gold (3TG) smelters and refiners in our supply chain conform with a recognized minerals certification program." It named RMAP as an example certification, but did not commit to only using RMAP conformant smelters.

The company published a list of smelters or refiners (SOR), however this was considered to be inadequate as it stated, "Because many of the suppliers for our in-scope products that provided country of origin and facility information provided this information to us for their entire supply chain, without specifying which facilities contributed gold, tin, tungsten, or tantalum used in components of the in-scope products, we are unable to validate the accuracy of the list”.

The company did not have evidence that it was increasing the use of recycled conflict minerals AND does due diligence on the source of recycled minerals.

Final scores are capped at either 0 or 100. Overall, Amazon.com Inc scored 40/100 for its approach to Conflict Minerals.