Hisonic, Conflict Minerals Policy
On August 22, 2012, the Securities and Exchange Commission (SEC) adopted section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Conflict Minerals Regulations”), which mandates that companies publicly disclose their use of certain minerals that originate from mines in the Democratic Republic of Congo (DRC) or adjoining countries. The goal of the act is to cut direct and indirect funding of any mines in the DRC that are controlled by armed militias responsible for humanitarian harm, including abuses against women and children. The minerals covered by the rule – coined conflict minerals – include tin, tantalum, tungsten and gold (3TG).
These conflict minerals are widely used in several manufactured goods and across many industries, including aerospace. Since the minerals in Hisonic products enter the supply chain through several sources of supply, and since Hisonic does not procure these metals directly from the mines or smelters, we must rely heavily on information from our suppliers to determine the origin of the minerals. Nonetheless, Hisonic is deeply committed to identifying the conflict minerals contained in our products in order to assist our customers in achieving compliance with the Conflict Minerals Regulations. It has always been Hisonic’s policy to comply with all applicable federal, state and local regulations including those relevant to our material acquisitions practices. Our education regarding Conflict Minerals Regulations will continue to evolve, as more information becomes available.
Hisonic Due Diligence Process
Hisonic has assembled a team of subject matter experts from within the organization to assist our customers in achieving compliance with the Conflict Minerals Regulations. The team has implemented several initiatives to date and will continue to assist our customers in providing information to support their due diligence processes as outlined within the Conflict Minerals Regulations.
Steps taken by Hisonic to date include:
- Included contractual language in our terms and conditions with suppliers.
- Adopted a reporting spreadsheet that aligns with the Organization for Economic Co-Operation and Development (OECD) standards.
- Surveyed our supplier base for Conflict Mineral information.
- Aggregated responses received into an initial response for Conflict Mineral inquiries.
- Updated our website to provide this policy and updated Supplier terms and conditions.
All Hisonic employees responsible for identifying Suppliers to Hisonic shall be aware of the restrictions on procurement of 3TG “Conflict Minerals” placed on some of our customers and shall endeavor to assure that the Hisonic supply chain is free of minerals originating from restricted areas. In addition, Hisonic shall fully cooperate with our customers by flowing down “Conflict Minerals” requirements to our Suppliers, and seeking and providing information to support their compliance with any regulations regarding “Conflict Minerals” Please direct any comments or questions regarding our support in compliance with Conflict Minerals Regulations to firstname.lastname@example.org.Hisonic 2019 Cmrt Ver 5