Conflict Minerals Policy Statement
In 2010, Congress enacted the Conflict Minerals provisions of the Dodd‐Frank Street Reform and Consumer Protection Act with the goals of eliminating the illegal trade in gold, tin, tantalum and tungsten (Conflict Minerals) and cutting the funding of armed groups in the Democratic Republic of the Congo (DRC) and its neighboring countries (Angola, Burundi, Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia) that are engaged in human rights abuses. Section 1502 of the Dodd‐Frank Act requires public traded companies to report to the U.S. Securities and Exchange Commission (SEC) and disclose on their website whether any of the Conflict Minerals in the products they manufacture or contract to manufacture originate in the DRC Region and the due diligence conducted to determine if the original sale of the mineral funded armed conflict. The SEC issued implementing regulations and guidance on August 22, 2012.
Environmental Technology’s (ETI) Commitment to Responsible Sourcing
ETI has built a legacy of operating and sourcing in an ethically and socially responsible manner. Today, ETI continues to be committed to ensuring our Fair and Square principles are honored in all of our business decisions. ETI is dedicated to preventing the sale of products produced at the expense of communities, workers or the environment. We are committed to sourcing products from companies that share our values around human rights, ethics, and social and environmental responsibility.
ETI fully supports the humanitarian goals of the Dodd Frank Act – eliminating illegal mineral trading and the funding of armed conflict while supporting legitimate commercial ventures. ETI does not directly purchase any Conflict Minerals from any source. Since the supply chain for Conflict Minerals is complex, we are committed to working with our supply chain to increase transparency regarding the origin and traceability of minerals contained in our products with the goal of ensuring that all products sold by ETI to our customers are “DRC Conflict Free.”
ETI will be carrying out supply chain due diligence consistent with the OECD guidelines. Suppliers of certain products will be required to complete the EICC‐GeSI Conflict Minerals Reporting Template.
ETI’s Expectations of Suppliers
Suppliers may not include in any products sold to ETI any tin, tantalum, tungsten or gold mined in the DRC or adjoining countries that fund armed conflict.
• Suppliers are required to develop Conflict Minerals policies, due diligence frameworks, and management systems, consistent with the Organization for Economic Cooperation and Development (OECD) guidelines and to drive those efforts throughout their supplier chain.
• Suppliers of certain products will be required to provide written evidence of due diligence documentation including completion of the EICC‐GeSI (Electronic Industry Citizenship Coalition – Global E‐Sustainability Initiative) Conflict Minerals Reporting Template.
To the extent available, Suppliers must use EICC‐GeSI designated Conflict‐Free Smelters as the source for any of the Conflict Minerals used in the products sold to ETI.
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