Conflict Minerals Compliance
Our Conflict Mineral Declaration
In response to the August 22, 2012 SEC final rule to implement the new disclosure requirements required by the July 21, 2010 Section 1502 of the Dodd-Frank Act, Analogic Corporation is conducting due diligence to determine what subcomponents may contain the listed “conflict minerals” columbite-tantalite (coltan), cassiterite, gold, wolframite and any of their respective derivatives (currently limited to tantalum, tin and tungsten) and if the minerals originated from the following “covered countries” which are the focus of the legislation: the DRC, Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
Section 1502 of the Act applies to all SEC reporting companies (both domestic and foreign private issuers) for whom conflict minerals “are necessary to the functionality or production” of a product manufactured or contracted to be manufactured by such entities.
Pursuant to the final rule adopted by the SEC on August 22, 2012, implementing requirements under Section 1502 of the Act, determining whether and how much disclosure is required is a three-step analysis:
- First, an SEC reporting company must determine whether any of the specified conflict minerals are necessary for the functionality or production of a product that it manufactures or contracts to manufacture.
- Second, if conflict minerals are necessary, the company must then make a “reasonable country of origin inquiry” as to whether the conflict mineral(s) originated in the covered countries. Companies required to undertake this inquiry must file a new Form SD with the SEC and must disclose their determination and briefly describe their inquiry and its results.
- Finally, if the company knows or has reason to believe that its conflict minerals may have originated in a covered country, the company must then also exercise due diligence on the source and chain of custody of its conflict minerals, in accordance with a nationally or internationally recognized framework where applicable, and disclose additional information to the SEC.
Analogic Corporation Compliance Position:
As a manufacturer of products including medical instruments, explosion detection systems, subsystems and process control systems, we have identified uses for each of the minerals of concern that are necessary for the functionality or production of our products.
Analogic’s Conflict Minerals Report sets forth the results of our most recent reasonable country origin inquiry.
It should be noted that Analogic Corporation does not directly source minerals from the DRC and the mines. The supply chain for the metals of concern consists of many tiers, including mines, traders, exporters, smelters, refiners, alloy producers and component manufacturers, before reaching Analogic’s direct suppliers. The combination of a lengthy, complex and regularly changing supply chain and the refining process makes it difficult to track and trace the minerals back to the mine of origin. For further information on our supply chain, click the link below.
Analogic strongly encourages our suppliers to implement responsible sourcing and to have them encourage smelters and refiners to obtain a ‘conflict-free’ designation from an independent, third-party auditor.