Conflict Minerals

This description provides further clarification of our working methods regarding the illegal trade of natural resources, in particular certain minerals known as conflict minerals.

We recognize the need to end the illegal extraction and trade of natural resources, as well as the associated human rights violations, conflicts, and environmental destruction that result from this trade. This is particularly critical in the region of the Democratic Republic of the Congo (DRC), due to certain illegal practices in the extraction and trade of ores containing tantalum, tin, tungsten, and gold that enter the global market through the DRC region. We take measures to increase transparency, ensure responsible sourcing, and drive positive change in this area.

We prohibit human rights violations related to the extraction, transport, or trade of minerals. We also prohibit direct or indirect support to non-state armed groups, security forces, or any other actor in the supply chain that illegally controls mines, transport routes, or trading points.

Likewise, we do not tolerate corruption, money laundering, or bribery. We require parties in our supply chain to agree to follow the same principles, and we work with our supply chain to improve the traceability of minerals and ensure responsible sourcing.

Suppliers who manufacture components, parts, or products containing tin, tantalum, tungsten, and/or gold must, upon request, declare that they only source materials from environmentally and socially responsible suppliers.

To comply with the rules and regulations issued by the U.S. Securities and Exchange Commission (SEC) in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, we review our supply chain to identify any minerals that may be classified as “conflict minerals” under SEC regulations. Information and declarations will be requested from suppliers where appropriate.

We have incorporated this approach into our supplier evaluation process and support industry initiatives such as the Conflict-Free Smelter Program (CFS) to validate that the metals used in our products do not contribute to conflict and originate from responsible sources. A list of validated smelters is available, and suppliers will be encouraged to source materials only from these validated smelters.

We continuously maintain and expand, where possible, our database with essential information and declarations from suppliers that use tin, tantalum, tungsten, and/or gold in their products.