CONFLICT MINERALS POLICY
In 2010, the Dodd-Frank Act became law. Section 1502, of the Act, requires publicly traded US companies to disclose the use of ‘conflict minerals’ required for the functionality of their products. Conflict Minerals come from the Democratic Republic of Congo and surrounding countries and include Tin, Tungsten, Tantalum and Gold (3TGs). The mining of these minerals has been partially co-opted by militant groups which engage in human rights abuses to mine these materials and use the proceeds to finance armed conflict in the region.
Consistent with our belief in the dignity of, and respect for, individuals, as demonstrated in our policies on labor practices; we are concerned with the humanitarian abuses involved in the mining of these materials and subsequent financing of armed conflict. As such, we strive to deliver products to our consumers manufactured in an ethical way consistent with our humanitarian beliefs and to be compliant with the laws in the countries in which we operate. To enable this, we have adopted the following practices:
- Instituted an assessment of its supply chain to identify areas where there is a high probability of 3TG use;
- Collaborate with suppliers to confirm 3TG usage and potential sources of these minerals;
- Work with its suppliers through the product development process to understand the risk of conflict minerals being incorporated into the design; and
- Expects its suppliers to adopt policies with respect to conflict minerals consistent with the company's stance.
In order to achieve these objectives, we developed a process consistent with the Organization for Economic Co-Operation and Development (OECD) framework for Conflict Minerals:
- Develop and implement systems and processes to understand level of conflict mineral risk in the supply chain. This includes the development of clear guidelines on the usage of conflict minerals for us and our suppliers which are communicated to all relevant stakeholders; as well as appointment of an internal management team to understand and manage the process with regard to conflict mineral due diligence in its supply chain;
- Assessment of the supply chain to understand where 3TGs may be used in our products;
- Develop an action plan to address those risk areas identified including: due diligence with identified suppliers, development of guidelines for product development processes to prevent the introduction of conflict minerals into our products and tracking and reporting of the results of these efforts;
- Auditing, performed by our Internal Audit team, of our processes as part of our normal internal controls process by our Internal Audit team; and
- Reporting of the results via the required Securities and Exchange Commission Form SD (Specialized Disclosure) and publishing those results on our website.