4. Reasonable Country of Origin Inquiry (RCOI) and RCOI conclusion:
We conducted an analysis of our products and found that the above SEC defined “conflict minerals”, which are tantalum, tin, tungsten, and gold (3TG), can be found in our products. Therefore, the products that we manufacture are subject to the reporting obligations of Rule 13p-1.
Despite having conducted a good faith reasonable country of origin inquiry, we concluded that our supply chain remains “DRC conflict undeterminable”. We have reached this conclusion because we have been unable to determine the country of origin of all of the 3TG supplied to SCI. We will continue to work with our suppliers.
5. Due Diligence Program
5.1. Conflict Minerals Policy
As a global supplier of advanced materials, SCI is committed to complying with the Conflict Minerals provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act, HR 4173, Section 1502 (Conflict Minerals Act). We will work with suppliers and take appropriate actions to ensure that our products do not contain conflict minerals. These actions will include conducting reasonable country of origin inquiries and, as necessary, obtaining reliable certificates of origin for all materials that might possibly originate in the Democratic Republic of the Congo (DRC) areas or an adjoining country.
The term conflict minerals generally refers to those minerals originating from the DRC and neighboring countries that may have directly or indirectly contributed to the financing of armed groups. These minerals include the 3Ts: Tantalum, Tin & Tungsten as well as Gold. Such armed groups may be responsible for violence and human rights violations in the DRC. We make purchases of 3TG minerals from the wholesale market for use in our products. Historically there has been no record to confirm the source of such wholesale minerals. We are working with our suppliers to identify the source of origin of the 3TG minerals used in our products. We will continue to exercise due diligence to ensure that SCI is fully compliant with the Conflict Minerals Act and will periodically post our findings in connection with our due diligence review.
There has been increased awareness regarding the human rights violations in the mining of certain minerals from an area known as the “Conflict Region”; the DRC and surrounding countries. Through the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, publicly traded companies have been chartered to practice reasonable due diligence with their supply chain to determine if “conflict minerals” used in their products are being sourced from mines controlled by non-government or unlawful military groups within the Conflict Region. Tracing materials back to their mine of origin is a complex endeavor but an important aspect of responsible sourcing.
We look to industry guidelines to help establish our programs such as the joint Electronic Industry Citizenship Coalition (EICC®). We continue to review our strategy to support the objectives of the U.S. regulations on the supply of “Conflict Minerals”. Our commitment includes:
●Continued development of policies and processes toward preventing the use of conflict minerals necessary to the functionality or production of our product(s) that finance or benefit armed groups in the Conflict Region.
●Not knowingly procure specified minerals that originate from facilities in the Conflict Region that are not certified as conflict free.
●Expecting suppliers whose products contain conflict minerals to establish policies, due diligence frameworks, and management systems consistent with our policies.
We believe in establishing and maintaining long-term relationships with suppliers whenever possible. However, if we determine that any supplier is, or a reasonable risk exists that it may be, violating this policy, then we will require the supplier to commit to devise and undertake suitable corrective action to move to a conflict free source. If suitable action is not taken, we will look to alternative sources for the product. Our efforts are not to ban procurement of minerals from the DRC and adjoining countries, but to assure procurement from responsible sources in the region. If