Background
In recent years there has been increased concern that the exploitation and trade of certain minerals originating in the Democratic Republic of the Congo ("DRC") and in the adjoining countries ("DRC Region") are helping to finance armed conflict characterized by extreme levels of violence. The term "conflict mineral" is defined as (1) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (2) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the DRC Region. These minerals are referred to as conflict minerals regardless of their country of origin. As required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, the U.S. Securities & Exchange Commission ("SEC") has adopted a rule to bring greater supply chain transparency to the use of conflict minerals originating from the DRC Region (the "Conflict Minerals Rule"). The Conflict Minerals Rule requires SEC registrants who manufacture or contract to manufacture products containing conflict minerals that are necessary to such products' functionality or production to disclose the origin and status of the conflict minerals.
Policy Statement
Kondex, together with its subsidiaries, is committed to corporate responsibility and to respecting human rights in its own operations and in its global supply chain. Kondex is committed to complying with the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk-Areas, as well as, in connection with its supply of products and components to public companies that are subject to the Conflict Minerals Rule. As part of that commitment, Kondex will seek to identify, reduce and ultimately eliminate the use in its products of conflict minerals that directly or indirectly finance or benefit armed groups in the DRC Region. Kondex is committed to ethical practices and compliance with applicable laws and regulations wherever it does business.
Kondex does not directly source conflict minerals from mines or smelters but uses refined metals in the manufacture of some of its products. Therefore, it relies on the information provided by its suppliers regarding their sourcing of metals. Kondex expects its suppliers to source materials from socially responsible suppliers and that all of its suppliers will comply with the Conflict Minerals Rule and provide all necessary declarations and supporting information. Suppliers must pass these requirements through to their supply chain if they do not source directly from mines or smelters and determine the source of the conflict minerals used in the product Kondex purchases.
To aid in our compliance, Kondex has adopted Supplier Guidelines that require applicable suppliers to Kondex of products containing conflict minerals to take commercially reasonable efforts to assist and cooperate with Kondex in connection with its efforts to comply with the Conflict Minerals Rule with respect to any products containing conflict minerals that are necessary to such products' functionality or production. These efforts will include providing assistance and cooperation with a country-of-origin inquiry for any conflict minerals necessary to the functionality or production of such products and providing Kondex with information and documentation reasonably requested by Kondex or any of its agents to assist it with compliance with the Conflict Minerals Rule with respect to such products.