Step 2: Identify and Assess Risk in the Supply Chain
Because of our size, the complexity of our products, the fact that many of our suppliers are small and unsophisticated, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. We rely on these suppliers to provide us with information about the source of any conflict minerals contained in the components supplied to us. Moreover, many of our direct and indirect suppliers are similarly reliant upon information provided by their suppliers. We continue to implement a risk-based approach that focuses on our most significant suppliers in 2023, which is substantially unchanged from prior years. As our program matures, we will continue to broaden our program to include all relevant suppliers.
Step 3: Design and Implement a Strategy to Respond to Risks
In response to this risk assessment, Bio-Techne instituted a risk management plan relating to our supply chain, through which risks are identified and mitigations developed. The conflict minerals program is implemented, managed and monitored through the RCOI due diligence plan.
As part of our risk management plan, to ensure suppliers understand our expectations, our purchasing management has provided the Template to relevant direct suppliers. The Template contains instructions, definitions and a questionnaire that must be completed and signed by an appropriate supplier signatory. We communicate with any of our suppliers when the source of the 3TG is unclear, as provided in the OECD guidance. When we identify a risk in the supply chain, we will engage with our direct supplier and develop a time frame in which the risk can be mitigated, which may include taking appropriate steps to transition procurement from a different supplier. To date, we have not yet terminated a contract or replaced a supplier for reasons solely related to conflict minerals compliance.
Step 4: Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. We support audits through our utilization in the CFSI. We did not, and are not required to, obtain our own independent private sector audit of this Report.
Step 5: Report on Supply Chain Due Diligence
In accordance with the OECD Guidance and the Conflict Minerals Rule, this Report is publicly available on our website at www.Bio-Techne.com.
5.Due Diligence Process and Results
Request Information
We continue to conduct surveys of suppliers using the Template. The Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. The Template includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters Bio-Techne’s suppliers use. In addition, the Template contains questions about the origin of conflict minerals included in a company's products, as well as supplier due diligence. The Template is being used by many companies in their due diligence processes related to conflict minerals.
Survey Responses
We reviewed our current list of suppliers in the relevant affiliates to identify those with likely 3TG content. We identified 163 suppliers who we thought might include 3TG in the components they supply to us and we distributed surveys to most of them. Of the 154 suppliers to whom we sent surveys, we received responses from 143 suppliers.
In a few cases, the suppliers confirmed that their products supplied to us did not include 3TG content. For those that did have 3TG content, some of the responses received provided data at a company or divisional level or the suppliers were unable to specify the smelters or refiners used for components supplied to Bio-Techne, such that additional follow up will be required. Consistent with a risk-based approach, we have or will focus our follow-up on the largest of the suppliers. As of the date of this filing, we have obtained compliance information on suppliers representing approximately 88% of our 3TG suppliers, either through completed survey responses or from compliance information available on the supplier websites. Some of the entities listed by our suppliers as smelters