1. The Company will notify suppliers of raw materials about the laws and regulations relating to conflict minerals and the Company’s procedures for compliance.
2. The Company will include language in each purchase order sent to a supplier of raw materials which will confirm that the product supplied pursuant to the relevant purchase order does not contain conflict minerals, was not sourced from the Democratic Republic of Congo or any of the surrounding countries (the “Subject Countries”) or was from scrap or recycled sources. If a supplier cannot give such confirmation because materials were sourced from one or more of the Subject Countries, the General Counsel and Director of Production Planning and Purchasing shall be notified so that additional due diligence can be conducted, as appropriate. The Company’s purchase order provides for audit rights, and the Company may periodically audit suppliers for compliance with the conflict minerals law and regulations.
3. The Company will obtain certification from each supplier of raw materials annually and with each shipment that the product supplied does not contain conflict minerals, was not sourced from the Democratic Republic of Congo or any of the surrounding countries or was from scrap or recycled sources.
4. The Company utilizes a nationally-recognized software service to track its and its suppliers’ compliance with the conflict minerals laws and regulations. The service provider undertakes an intensive due diligence process for each supplier, including, a risk assessment in which the Company is extensively involved, obtaining a Conflict Minerals Reporting Template (“CMRT”) for each in-scope supplier, automated supply chain outreach outlining any validation issues with each CMRT or missing fields, smelter follow-up with suppliers, outlining any high risk smelters, identified by the supplier, follow-up on invalid CMRTs, supplier outreach escalation and smelter research and outreach, including smelter validation and encouragement to enroll in the RMAP.