NRG Energy | Strategic Supplier Sourcing: Conflict Minerals
Standards and policies
The NRG Standard Terms and Conditions require that suppliers comply with all applicable laws and regulations. The Standard Terms and Conditions can be found here.
We conduct audits of all treatment, storage and disposal (TSD) facilities where our hazardous, industrial and universal waste streams are disposed. We work closely with our waste suppliers to identify and audit their TSD facilities before commencing services. The focus of the audit is primarily environmental compliance, ensuring that both the supplier and TSD facility are compliant with all applicable laws and regulations. We have strategic relationships with a limited number of waste suppliers whose TSD facilities are audited every five years to maintain compliance. Because of the environmental sensitivity of waste hauling, we maintain strategic relationships with key waste suppliers and do not regularly add new waste suppliers to our supply chain.
Most high-volume materials are purchased by various units of measure with no direct correlation to weight or volume. With the exception of 26 miles of transmission from our wind farms, NRG does not own or operate distribution. Materials used in the generation of electricity include fuel, chemicals for wastewater treatment and air quality control equipment and maintenance. We have a chemical management plan in place that covers reviewing all chemicals before they can be used on-site; managing the handling and delivery of chemicals to ensure best practices and avoid the need for disposing of chemicals past their shelf life; secondary containment; and emergency response. Any transformers or PCB-containing equipment on our property were converted to non-PCB materials a number of years ago.
In September 2014, NRG acquired Goal Zero, a provider of portable solar power and battery pack products and accessories. Goal Zero conducted an analysis of the materials used in the production of its products and determined that substantially all of its products may contain conflict minerals. Conflict minerals are tin, tantalum, tungsten and gold and are referred to as 3TGs.
Goal Zero’s supply contracts require suppliers to represent and ensure that they supply Goal Zero with only 3TGs that are “conflict free” unless otherwise agreed to by Goal Zero. Goal Zero also requires that its suppliers agree that they will inform all of their own suppliers of this policy and ensure that it is complied with throughout the supply chain. Goal Zero reserves the right, in its contracts, to audit its suppliers’ compliance at any time and to terminate supply agreements if there is a material breach of the agreement.
In addition, in 2016, NRG adopted manufacturing standards that all Goal Zero suppliers will be required to comply with. The standards address compliance with laws and regulations and require suppliers to abide by the applicable laws and regulations of the country in which they do business, including, but not limited to, laws related to labor practices, health and safety, environmental responsibility and anti-corruption. The standards also set requirements based on industry best practices and international conventions, including those related to 3TGs.
Goal Zero does not directly manufacture any products. Goal Zero contracts for the manufacture and assembly of its products through a competitive global supply process. The suppliers then source both raw materials and purchased parts. Goal Zero has 16 direct material suppliers globally, and there are generally multiple tiers between the 3TG mines and Goal Zero’s direct suppliers. Therefore, we rely on the direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to Goal Zero, including sources of 3TGs that are supplied to them from lower-tier suppliers. Contracts with Goal Zero’s suppliers are frequently in force for multiple years, and we can’t always unilaterally impose new contract terms and flow-down requirements. As we enter into new contracts, we require Goal Zero’s suppliers to provide information about the presence of conflict minerals in the products supplied and about the smelter sources of any conflict minerals. Read the full report submitted to the SEC here.
NRG is the leading integrated power company in the U.S., built on the strength of the nation’s largest and most diverse competitive electric generation portfolio and leading retail electricity platform. A Fortune 200 company, NRG creates value through best in class operations, reliable and efficient electric generation, and a retail platform serving residential and commercial businesses. Working with electricity customers, large and small, we continually innovate, embrace and implement sustainable solutions for producing and managing energy. We aim to be pioneers in developing smarter energy choices and delivering exceptional service as our retail electricity providers serve almost 3 million residential and commercial customers throughout the country.