Ref: Inquiries on – Conflict Metals or Dodd-Frank Wall Street Reform and Consumer Protection Act in 2010: Section 1502 – Conflict Minerals.
ElectroLab undertakes due diligence to attempt to determine if use of any of the “conflict minerals” in our products directly or indirectly finance or benefit armed groups. Federal law defines “conflict minerals” as (i) 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 (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (collectively known as the “Covered Countries”).
ElectroLab is well into the process of carrying out the appropriate supply chain due diligence guidance, with regard to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, to make this determination. As part of the process for the engagement of new suppliers, ElectroLab is using the EICC-GESI Conflict Minerals Reporting Template and other tools, including our own sustainability questionnaires, to require direct confirmation that any “conflict minerals” in materials we purchase do not support armed groups in the Covered Countries and suppliers must also make a declaration that their full supply chain has been duly examined to confirm this. It is anticipated that third party auditors will be engaged to confirm answers given by material suppliers.
In addition, we have also reviewed our existing supply base, in particular suppliers of materials that contain “conflict minerals”. We can confirm that at this time there is no indication that any products we manufacture contain minerals that directly or indirectly finance or benefit armed groups in the Covered Countries.
ElectroLab is in the process of fully implementing its “conflict minerals” program in due course. We also understand the livelihoods of many people are dependent upon the safe and legitimate extraction of these minerals. Against this background, we do not intend to ban or cease the use of these minerals, provided it can be demonstrated that they do not originate from sources that directly or indirectly finance or benefit armed groups.