The Conflict Minerals Rule, which was adopted under the Dodd-Frank Wall Street Reform and Consumer Protection Act, requires annual disclosure and reporting on the source and use of conflict minerals (“Conflict Minerals”), which refer to tantalum, tin, tungsten, or gold (“3TG”) that originate in the Democratic Republic of Congo (“DRC”) or adjoining countries (“Covered Countries”). Publicly traded companies that manufacture or contract to manufacture any products containing 3TG that are necessary to the functionality or production of their products must exercise reasonable diligence to determine the source of origin and chain of custody of such necessary 3TG and report their findings annually to the U.S. Securities and Exchange Commission (“SEC”). The Conflict Minerals Rule is intended by Congress to address the concern that the exploitation and trade of Conflict Minerals from the Covered Countries is helping to finance the ongoing conflict and humanitarian crisis in the DRC region.
As a company that provides procurement and manufacturing services to clients that are publicly traded, SupplyLogic, LLC dba SLWM (”SLWM”) hereby attests that it does not directly source any 3TG from mines, smelters, or refiners, and is several steps removed from the melting, smelting, and refining of 3TG. To the best of our knowledge, the products that we procure or manufacture for our clients do not contain any Conflict Minerals or their derivative. We therefore require the cooperation of our suppliers with this policy to enable us to assist our clients in meeting their SEC compliance obligations.
SLWM has the following expectations of its suppliers for products that we contract with them to manufacture:
- We expect our suppliers to promptly, completely and accurately respond to our informational requests with respect to any 3TG contained in products that are likely to include 3TG, including by providing a written attestation that the products provided to SLWM and its clients do not contain any Conflict Minerals that originated in the Covered Countries.
- We expect our relevant suppliers to (1) determine whether there is any 3TG in any products supplied to SLWM and its clients, (2) survey their upstream suppliers regarding Conflict Minerals and work with them to determine the ultimate source or chain of custody of any products containing 3TG, and (3) verify and document such information.
- At SLWM’s request, relevant suppliers will provide a description of the products containing 3TG, facilities, country of origin, and efforts to determine mine or location of origin, including survey responses from upstream suppliers.
- We expect our relevant suppliers to implement policies, due diligence frameworks and management systems to support compliance with these expectations, and require their upstream suppliers to adopt similar policies, frameworks and systems.
- We expect our suppliers to cooperate in the event we determine that any further inquiry or due diligence is required or advisable with respect to the traceability of any Conflict Minerals, and promptly implement any corrective actions identified and requested by SLWM.
SLWM believes in establishing and maintaining long-term relationships with suppliers whenever possible. However, if we determine that a supplier may be violating this policy, we may require them to commit to and implement a corrective action plan within a reasonable timeframe, or we may terminate our business relationship with such supplier. Nothing contained in this policy shall be interpreted to preclude SLWM from terminating any supplier relationship at any time for any reason.
Concerns or comments regarding this policy, or suspected violations of this policy, can be reported to compliance@slwmco.com.
Last Modified: February 16, 2023