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Conflict Minerals Management Policy

Chemtronics Co., Ltd.’s No Conflict Minerals Policy

Conflict minerals refer to the metals tin, tantalum, tungsten, and gold extracted in the Democratic Republic of the Congo or its adjoining countries involved in conflicts.
The funds generated from the conflict minerals finance armed groups in such countries, possibly causing violation of human rights through child labor, forced labor, and abuse of women during the mining process. Amid the increasing international concern on the matter, the US Congress passed the Act in 2010 that makes the report on the use of conflict minerals mandatory (the Dodd–Frank Wall Street Reform and Consumer Protection Act). In accordance with Section 1502 of the Act, US publicly listed companies should audit their supply chains and report conflict minerals usage and their country of origin to the US SEC (Securities and Exchange Commission).

As a responsible enterprise, Chemtronics Co., Ltd. will make sure that conflict minerals related to armed groups in the troubled regions will not be included in its supply chain for the production of the Company’s products.
Chemtronics Co., Ltd.’s Conflict Mineral Management Plan
  • The Company will establish the conflict minerals task process in compliance with the law based on the international standard. It will actively cooperate in activities of banning the usage of conflict minerals of EICC (the Electronic Industry Citizenship Coalition) and GeSI (Global e-Sustainability Initiative).
  • Using the EICC-GeSI questionnaire on the conflict minerals usage report, the Company will clarify the names and locations of smelters of tin, tantalum, tungsten, and gold used in its products.
  • The Company will require the submission of the questionnaire on conflict minerals usage report and the non-use confirmation certificate from companies utilizing 3TG metals (tin, tantalum, tungsten, and gold).
  • The Company will urge its subcontractors to purchase conflict minerals from smelters certified by the Conflict-Free Smelter Program.
  • According to the internal standard of audit, the Company will conduct the evaluation on its subcontractors regarding conflict minerals.
Chemtronics Co., Ltd. applies the same criteria for its conflict mineral management to all subcontractors and requires them to be well-informed of laws related to conflict minerals and to abide by Chemtronics Co., Ltd.’s Conflict Minerals Management Policy.
  • Subcontractors should submit a written conflict minerals report to Chemtronics Co., Ltd. to make sure that the conflict minerals financing armed groups in the Democratic Republic of Congo or its neighbors are not included in the supplied products.
  • Subcontractors should make efforts to obtain the information on the smelter and country of origin of their purchased 3TG materials (tin, tantalum, tungsten, and gold).
  • If a problem occurs in relation to conflict minerals, subcontractors should take corrective action. Chemtronics Co., Ltd. can cease trading with a subcontractor if it fails to offer the necessary information for the confirmation of conflict minerals usage, provides false information, or fails to take corrective action following the occurrence of a problem.
Chemtronics Co., Ltd. will actively participate in efforts to curb conflict minerals usage together with its subcontractors and clients.