CONFLICT MINERALS POLICY

Introduction:

In 2010 the Dodd-Frank Consumer Protection Act, section 1502 was signed into law. Section 1502 addresses the international trade and use of Conflict Materials. Conflict Materials are defined as tin, tantalum, tungsten and gold mined by armed groups from the Democratic Republic of the Congo and adjacent countries known as the DRC region. Proceeds from the sale of these minerals have financed violence and human rights abuses within this region The Dodd-Frank Consumer Act requires the disclosure and the identification of a company’s supply chain and purchases of these minerals.

Scope: 

Companies subject to SEC requirements that use Conflict Minerals from the Democratic Republic of the Congo.

Commitment:

  • To conform to the objectives of the U.S. legislation and SEC rules set forth by the Dodd-Frank Wall Street and Consumer Protection Act relating to the use of Conflict Minerals.
  • Perform due diligence during the design of products and purchase of minerals used within those products.
  • To post this policy on our company website and to communicate the Conflict Mineral requirement to our suppliers.

Expectations of Our Suppliers:

  • To perform due diligence and comply with the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to the use of Conflict Minerals.
  • Annually disclose whether any of the minerals originated in the Democratic Republic of the Congo or an adjoining country.
  • Adopt a policy that facilitates compliance with the current regulatory requirements.

Reference/Informational Links

www.sec.gov/rules/final/2012/34-67716.pdf