Under the terms of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”) all publically traded companies subject to SEC rules are required to report conflict minerals (gold, tantalum, tungsten and tin, and the derivatives of cassiterite, columbite-tantalite and wolframite (“conflict minerals”)) used in the products they manufacture or contract to manufacture which are sourced from conflict areas of the Democratic Republic of Congo and its nine adjoining countries (the “DRC”). The Act aims to prevent the use of minerals from the DRC which finance armed groups tied to human rights violations in the DRC.
Although Ensign-Bickford Aerospace & Defense (EBAD) is not a public company required to report under the Act, we are committed to assisting our customers meet their respective conflict mineral reporting obligations. We feel a sense of corporate responsibility to assist in the efforts to end violence and human rights violations in the DRC and have therefore: (i) formally adopted a conflicts mineral policy which we will continue to develop, as necessary; (ii) established an internal cross functional team to vet and address concerns regarding conflict mineral reporting and compliance; (iii) posted this conflict mineral statement on our website; and (v) made our conflict mineral policies known to our employees, including procurement personnel responsible for managing relationships with our suppliers and purchasing raw materials.
Our conflict mineral policy values responsiveness to customers and transparency. With respect to our suppliers providing components or parts used in our production process, EBAD has updated its standard terms and conditions to include language regarding conflict mineral reporting. EBAD performs due diligence inquires as to: (i) suppliers we use which have been identified as higher risk suppliers, and (ii) suppliers which provide us with components or products EBAD incorporates into products we sell to customers which have requested confirmation from EBAD regarding conflict mineral reporting. If through our due diligence inquires, we find that there are minerals we use or components we procure which utilize minerals originating from a non-conflict free area, we will seek to transition away to suppliers who can confirm they are conflict free. If no acceptable alternative can be found, we will notify our customer.