The ores from which gold, tantalum, tin and tungsten (“conflict minerals”) are derived that come from the Democratic Republic of Congo (“DRC”) and adjoining countries (the “Covered Countries”) may be making their way into the defense and security industry supply chain. There is concern that mining activities in these Covered Countries are fueling conflict and human rights abuses by directly or indirectly financing armed groups. As part of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, the United States Securities and Exchange Commission (“SEC”) adopted rules that require SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of such registrant’s products to report on the origin of these conflict minerals.
While we do not source these metals directly, they may exist in the materials and components we source for our manufactured products. We are therefore committed to complying with the SEC’s reporting regulations relating to conflict minerals.
Due to the complex nature of our products and supply chain, the process of tracing the conflict minerals through the supply chain is complicated. We continue to develop systems and practices to efficiently gather information from suppliers to trace the source of conflict minerals in the supply chain, collect data that we and our customers need for compliance with the SEC reporting requirements, and maintain, as necessary and appropriate, records of supplier verifications for both internal and/or external audit. We will rely on industry initiatives for assistance in complying with the SEC reporting requirements on conflict minerals. We will work towards engaging suppliers whose products contain conflict minerals to establish policies, due diligence frameworks, and management systems that are designed to accomplish this goal, and require their suppliers to do the same.