Conflict Minerals Compliance
Conflict Mineral Compliance Statement
One of the biggest concerns in the technology industry is the fair and ethical use of components sourced from known conflict-affected areas. Analogic recognizes the complexity of using these minerals and willingly provides this conflict minerals disclosure statement.
On August 22, 2012, the Securities and Exchange Commission issued a final rule to implement the new disclosure requirements around consumer protection required by the July 21, 2010 Section 1502 of the Dodd-Frank Act — a massive finance reform and consumer protection act. Part of this act is a brand new ruling on conflict minerals compliance.
Analogic Corporation conducts regular due diligence to determine what subcomponents may contain the listed “conflict minerals”:
- columbite-tantalite (coltan)
- raw materials
- any of their respective derivatives (currently limited to tantalum, tin, and tungsten)
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, they are subject to OECD due diligence guidance.
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.
According to the final rule adopted on August 22, 2012, implementing requirements under Section 1502 of the Act to determine whether — and how much — disclosure is required through a three-step analysis:
- First, an SEC filings report 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 and high-risk areas.
- 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 measures 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 raw materials and scrap sources, including medical instruments, explosion detection systems, subsystems and process control systems, we have identified uses for each of the minerals of concern. These 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 and outlines our steps to ensure that we remain compliant with the responsible minerals initiative.
It should be noted that Analogic Corporation does not directly source minerals from the Democratic Republic of the Congo 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 a due diligence framework, and to have them encourage smelters and refiners to obtain a ‘conflict-free’ designation through an independent, third-party audit.
Economic co-operation is necessary to maintain the spirit of this conflict minerals regulation. Analogic remains dedicated to responsible sourcing, helping to ensure that our clients receive our manufactured products in good faith with the Securities and Exchange Commission.
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