Conflict Minerals Policy

Conflict Minerals Policy

 

Policy

Microwave Distributors Company is committed to the protection of human rights and the promotion of high ethical business standards.  Accordingly, Microwave Distributors Company supports the humanitarian goal of ending the armed conflicts in the Democratic Republic of the Congo and its adjoining countries (collectively, the "DRC Countries"), which are partially financed by the exploitation of "conflict minerals" (as defined in 17 C.F.R. ∫240.13p-1(d)(3)) sourced from DRC Countries. 

Verification Approach

Towards that end, and in consideration of the disclosure requirements of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (P.L. 111-203,  ∫1502), Microwave Distributors Company set up an internal team in 2013 to develop an approach to implement due diligence measures designed to determine the source of conflict minerals necessary to the production or functionality of products manufactured by Microwave Distributors Company, distributed by Microwave Distributors Company, or which Microwave Distributors Company contracts to manufacture (collectively, "Affected Products").

Microwave Distributors Company's verification process consists of:

  • Requiring Microwave Distributors Company's direct suppliers to certify that components of Affected Products sold to Microwave Distributors Company either (i) are "DRC conflict-free" (as defined in 17 C.F.R. ∫240.13p-1(d)(4)), or (ii) contain only conflict minerals sourced from smelters validated as compliant to CFS protocol using the CFS Compliant Smelter List.
  • Requesting Microwave Distributors Company's direct suppliers of Affected Products to verify the accuracy of a completed standard conflict minerals reporting template, which is based on the industry-accepted Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative Conflict Minerals Reporting Template, and the responsiveness or non-responsiveness of the direct suppliers in accordance with such requests can result in a downgrade of the direct suppliers rating.

Reports

Microwave Distributors Company is pleased to provide our customers with a completed Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative Conflict Minerals Reporting Template upon request.

Declarations and Determinations

Based on Securities and Exchange Commission Official Release No. 34-67716, Microwave Distributors Company has determined and assumes that it does not contract to manufacture the commercial-off-the-shelf ("COTS") components of its parts because Microwave Distributors Company does not exert sufficient influence over the materials, ingredients, or sub-components contained therein.  Accordingly, conflict minerals contained in COTS components of Microwave Distributors Company's parts are excluded from conflict mineral declarations made by Microwave Distributors Company.

In addition, these declarations are based on and made subject to: (a) Microwave Distributors Company's standard Supplier Quality Clauses with its direct suppliers, which requires that all products sold to Microwave Distributors Company are either (i) "DRC conflict-free" (as defined in 17 C.F.R. ∫240.13p-1(d)(4)), or (ii) contain only conflict minerals sourced from smelters validated as compliant to CFS protocol using the CFS Compliant Smelter List, and the responsiveness or non-responsiveness of the direct suppliers in accordance with such Supplier Quality Clauses; (b) The responsiveness or non-responsiveness of Microwave Distributors Company's direct suppliers to Microwave Distributors Company's standard conflict minerals supplier certification in accordance with such certification , which is based on the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative Conflict Minerals Reporting Template.

Inquiries

Inquiries concerning conflict minerals should be forwarded to: instock@microwavedistributors.com.

 

 

 



© 2016 Microwave Distributors Company. All Rights Reserved.