On August 22, 2012, the U.S. Securities and Exchange Commission (SEC) adopted final rules to implement reporting and disclosure requirements concerning Conflict Minerals, as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. These rules require manufacturers that file certain reports with the SEC to disclose in a new “Form SD” filing whether the products they manufacture or contract to manufacture contain Conflict Minerals that are “necessary to the functionality or production” of their products – and to report on their process to identify the source of those Conflict Minerals.
“Conflict Minerals” currently include gold, cassiterite, columbite/tantalite, and wolframite, specifically tin, tantalum and tungsten, regardless of where these minerals are mined, processed or sold. The U.S. Secretary of State may designate other minerals in the future.
The requirements regarding Conflict Minerals were enacted to further the humanitarian goal of ending violent conflict and human rights abuses in the Democratic Republic of the Congo and the surrounding countries of Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (referred to as the Covered Countries), which have been partially financed by the exploitation and trade of Conflict Minerals. Haemonetics is supportive of efforts to enable supply chain transparency and responsible sourcing.
Starting in May 2014, Haemonetics is required to report annually to the SEC with respect to its Conflict Minerals due diligence process. All global suppliers that provide parts contained in Haemonetics products are required to support this effort. Specifically, suppliers are required to respond to a regular survey to identify whether products they manufacture or contract to manufacture for Haemonetics contain any Conflict Minerals necessary to the functionality or production of their products. If any Conflict Minerals are contained in the affected product supplied to Haemonetics, the supplier will be required to determine the country of origin of these materials and whether the Conflict Minerals can be identified as “conflict free,” and to report this information to Haemonetics.
Haemonetics will continue to assess the presence of Conflict Minerals in our supply chain. We will educate employees and suppliers about this Conflict Minerals Policy and clearly communicate expectations with regard to supplier performance, transparency and sourcing. We will compare our supplier survey results to information collected via independent conflict free smelter validation programs such as the EICC/GeSI Conflict Free Smelter program.