CLEARFIELD POLICY STATEMENT REGARDING CONFLICT MINERALS
The Dodd-Frank Wall Street Reform and Consumer Protection Act, passed into law in July 2010, contains language requiring publicly listed U.S. companies to report to the Securities and Exchange Commission (SEC) on the origins of “Conflict Minerals” (Gold, Tin, Tungsten and “Tantalum”) used in their products, and demonstrate due diligence to avoid sourcing these materials from the Democratic Republic of the Congo (DRC) or “adjoining countries”, including Angola, Burundi, the Central African Republic, Rwanda, South Sudan, Tanzania, Uganda, or Zambia. The goal of this act is to eliminate direct or indirect funding of armed groups engaged in violent acts and human rights abuses against the populations of these regions.
Clearfield does not directly source any of these minerals for use in our products. However, these minerals are commonly included in many components, subassemblies, and materials used in the electronics and cable industries, including some sourced and used by Clearfield, and even though we and our suppliers are many tiers removed from the actual mining operations in these countries, Clearfield is still committed to the ideals of the Dodd-Frank regulations and avoiding the purchase of products that contain minerals from mines in this conflict region.
To meet our obligations, Clearfield has implemented this corporate policy statement regarding Conflict Minerals. This policy requires:
- That Clearfield performs due diligence reviews of our supply chains to ensure transparency regarding the origins of any these minerals in our products.
- That records of these reviews, including origin inquiries and corporate material declarations from our suppliers will be maintained in accordance with SEC requirements.
- That our suppliers comply with the Dodd-Frank regulations, can demonstrate that they understand and are willing to comply with these, and that they pledge not to knowingly source materials from the DRC or adjoining countries.
- That suppliers pass the Conflict Minerals requirements along through their supply chains in order to determine origin of these materials, and that appropriate records of these inquiries are maintained and provided to Clearfield upon request.
- That suppliers who do not comply with these requirements shall be reviewed for continuing business, and loss of said business will likely result.