CONFLICT MINERALS POLICY
Our company supports ending human rights violations in the mining of conflict minerals from an area described as the “Conflict Region”, which is situated in the eastern portion of the Democratic Republic of the Congo (DRC) and surrounding countries. The U.S. Securities and Exchange Commission (“SEC”) adopted final rules to implement reporting and disclosure requirements related to “conflict minerals,” as a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The rules require manufacturers who file certain reports with the SEC to disclose whether the products they manufacture or contract to manufacture contain “conflict minerals” that are “necessary to the functionality or production” of those products.
The definition of “conflict minerals” includes gold, tin, tantalum, and tungsten, which are the derivatives of cassiterite, columbite-tantalite, and wolframite, regardless of where they are sourced, processed or sold. The U.S. Secretary of State may designate other minerals in the future. We support the aims and objectives of the U.S. legislation on the supply of “conflict minerals”.
In addition, we are committed to not knowingly purchase specific metals that originate from the facilities in the “Conflict Region” that are not certified as “conflict free”. We ask our suppliers to perform due diligence within their supply chains so that the minerals in question are sourced only from mines and smelters outside “Conflict Region; or those mines and smelters that have been certified as “conflict free” by an independent third party.
This due diligence includes but is not limited to requiring our suppliers to complete and submit a “Conflict Minerals Survey”. Our goal is to ensure that only “conflict free” materials are used in products that we procure