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. Part of this act is a ruling on conflict minerals compliance.
Analogic Corporation conducts regular due diligence to determine what subcomponents may contain the listed 3TG “conflict minerals”:
Minerals originated from the following “covered countries” are subject to OECD due diligence guidance which are the focus of this legislation: the Democratic Republic of the Congo (DRC), Angola, Burundi, the Central African Republic, 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.
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:
While Analogic Corporation is not a public entity required to file with the SEC, we are committed to meeting the intent of the Dodd-Frank rule, and additional regulatory and voluntary programs that may be requirements of our customers. We are committed to complying with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHAs). Analogic recognizes that we have a responsibility to not contribute to armed conflict or human rights abuses wherever violations might occur. This expands our due diligence beyond the DRC and surrounding countries to a global scope, while also including risk attributes listed in Annex II of the OECD Guidance:
It should be noted that Analogic Corporation does not directly source minerals from mines, which are typically several tiers removed from our direct suppliers, thus we do not directly source any from the DRC or surrounding countries, nor any conflict affected and high-risk areas (CAHRAs).
As a manufacturer of medical instruments, explosion detection systems, subsystems and process control systems, we have identified uses for each of the minerals of concern. In some cases these are necessary for the functionality or production of our products, in other cases they are simply included in standard purchased components that are part of our supply chain but not explicitly specified.
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.
Analogic reports annually on its responsible minerals initiative due diligence program in line with regulatory and voluntary global programs. See report below.
Analogic Conflict Minerals Report
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. Our conflict minerals supply chain due diligence program is designed in line with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and its supplements (OECD Guidance). Drawing upon the Five-Step approach described in the OECD Guidance, we established a system of control and transparency over 3TG supply chains by creating a process to engage suppliers, assess their due diligence efforts, and identify smelters.
a) by adopting procedures integrated in its own company management system;
b) by requiring its own Suppliers to adhere to the same principles of due diligence;
c) by identifying the risks through its supply chain mapping allowing to trace the conflict mineral origin and in particular the origin of the foundries certified by an independent third-party;
d) by starting a reactive dialog with the actors downstream the supply chain in order to mitigate the identified risks;
e) by making this policy public by publishing it on its website.”
Economic co-operation is necessary to maintain the spirit of this responsible minerals initiative. Analogic remains dedicated to responsible sourcing, helping to ensure that our customers receive our manufactured products in good faith with the Securities and Exchange Commission and other global programs.
Contact us at info@analogic.com. Our response to such requests will be limited to information under our direct control. We will make reasonable efforts to respond promptly to such requests in accordance with applicable laws.
