Conflict mINERals policy statement
Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) enacted in July 2010 imposes certain reporting obligations on Securities and Exchange Commission (SEC) registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as tin, tantalum, tungsten, and gold that originates from the Democratic Republic of the Congo (DRC) or an adjoining country.
As directed by the Dodd-Frank Act, the SEC has adopted rules requiring publicly traded companies to disclose whether they use tantalum, tin, gold and tungsten that originated in the DRC or an adjoining country and if so, to issue a report identifying their products that are not conflict free and their due diligence efforts to determine the source and chain of custody of the metals. Conflict Free means the product does not contain tantalum, tin, gold and tungsten that directly or indirectly finances or benefits armed groups in the DRC or an adjoining country.
AOI supports efforts to eliminate the use of tantalum, tin, gold and tungsten from improper sources that could promote such serious problems in the DRC and adjoining countries.
Accordingly, AOI’s policy on Conflict Minerals is:
- AOI strives to have a Conflict Free supply chain, and is committed to sourcing products and materials from conflict-free sources
- AOI expects our vendors to have policies and processes in place to be able to trace the source of their materials and products to ensure that any Conflict Minerals contained in products we purchase from our vendors do not originate from conflict mines within the DRC and the surrounding region
AOI will provide applicable vendors with the standardized Electronic Industry Citizenship Coalition/Global E-Sustainability Initiative (EICC/GeSI) Conflict Minerals Reporting Template (CMRT) that traces the metals back through the supply chain. AOI also supports industry initiatives such as the Conflict-Free Sourcing Initiative (CFSI) Conflict Free Smelter Program (CFSP) to validate responsible and sustainable sources. Our objective is to have a conflict-free supply chain. If AOI becomes aware of a vendor whose supply chain includes metals from a conflict source, AOI will take the appropriate actions to remedy the situation in a timely manner, including reassessment of vendor relationships, to achieve that objective. AOI expects our vendors to take similar measures with their vendors to ensure alignment throughout the supply chain.