Whitepath Fab Tech - Conflict Minerals Policy
Pursuant to the Dodd-Frank Act, the SEC issued their final ruling regarding the reporting requirements for conflict minerals obtained from the Democratic Republic of Congo (DRC) and the Covered Countries. These minerals include tantalum, tin, gold, and tungsten.
Although Whitepath Fab Tech does not report to the SEC, our customers require us to provide information regarding the use of conflict minerals.
Because Whitepath Fab Tech does not source conflict minerals directly from smelters or refiners and has a multi-tiered and geographically dispersed supply chain, engagement with our suppliers is a fundamental element of our efforts to comply with these requirements.
Whitepath Fab Tech will seek to responsibly source materials and to avoid supporting the armed groups causing human rights violations. Thusly, Whitepath Fab Tech expects our suppliers to:
- Source conflict minerals responsibly and to provide sufficient data, including supporting due diligence records, demonstrating they have ensured that, to the extent they use conflict minerals in the products they provide to Whitepath Fab Tech, the procurement of those conflict minerals does not support these armed groups and are DRC Conflict Free;
- Establish conflict minerals compliance policies, survey their suppliers and establish a due diligence process to support their conflict minerals data collection efforts; and
- Document thoroughly their efforts to determine the source of any conflict minerals or derivatives and be prepared to provide Whitepath Fab Tech with evidence of the origin of any conflict minerals contained in products supplied to Whitepath Fab Tech.
Whitepath Fab Tech requires the use of the EICC Conflict Minerals Reporting Template (CMRT). When requested by Whitepath Fab Tech, suppliers are to provide the most up to date list of smelters that provide these metals to the supply chain. Unless otherwise specified, the latest version of the template is required.
The supplier is required to fill out the template in its entirety to the best of their ability. Answer all questions at the product level rather than company level. If the supplier is currently unsure of the answer to a question, they should respond "unknown" or "uncertain" and provide an explanation.
Please note: even if the supplier's response is "No" for all four minerals, the supplier is required to complete the company level questions at the bottom of the form for due diligence purposes.
Whitepath Fab Tech advises suppliers that additional information on the EICC (CMRT) template can be found on the Conflict Free Smelter site at www.conflictfreesmelter.org.