The Atrix Stance on Conflict Minerals

We support ending the violence and human rights violations in the mining of certain minerals from a location described as the “Conflict Region,” which is situated in the Democratic Republic of the Congo (DRC) and surrounding countries where revenues may be directly or indirectly financing armed groups engaged in civil war resulting in serious social and environmental abuses.

The U.S. Securities and Exchange Commission (SEC) adopted final rules to implement reporting and disclosure requirements related to “conflict minerals,” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

Although the rules require publicly traded companies to disclose whether products they manufacture or contract to manufacture contain these “conflict minerals,” these requirements are cascading through the whole supply chain.

The definition of “conflict minerals” refers to gold, tin, tantalum and tungsten, the derivatives of cassiterite, columbite-tantalite and wolframite, regardless of where they are sourced, processed or sold. We support these requirements to further the humanitarian goal of ending violent conflict in the DRC and in surrounding countries, which has been partially financed by the exploitation and trade of “conflict minerals.”

 

Our Commitment:

  1. Support the aims and objectives of the U.S. legislation on the supply of “conflict minerals.”
  2. Do not knowingly procure specified metals that originate from facilities in the “Conflict Region” that are not certified as “conflict free.”
  3. Ensure compliance with these requirements, and ask our suppliers to undertake reasonable due diligence with their supply chains to assure that specified metals are being sourced only from:
    Mines and smelters outside the “Conflict Region” OR
    b. Mines and smelters which have been certified by an independent third party as “conflict free” if sourced within the “Conflict Region.”

This due diligence includes having our suppliers provide evidence documenting raw materials used to produce these “conflict minerals,” used in the materials to manufacture components and products supplied to Atrix, originate outside the “Conflict Region” OR if they originate from within the “Conflict Region,” that the mines or smelters be certified “conflict free” by an independent third party. The aim is to ensure that only “conflict free” materials and components are used in the products that we procure.

If we discover the use of minerals produced in facilities that are considered to be “non-conflict free,” in any material, parts or components we procure, we will take appropriate actions to transition the product to be “conflict free.”

If you would like to download the PDF version of this policy, please visit this link: Conflict Minerals Policy Statement