CONFLICT MINERALS POSITION STATEMENT
The United States Congress has associated the extraction and trade of tin, tungsten, tantalum, and gold (“Conflict Minerals”) with human rights violations in the Democratic Republic of the Congo and adjoining countries (collectively, the “DRC”). Flexxaire is committed to the responsible sourcing of Conflict Minerals used in our products. With regard to the extraction and trade of Conflict Minerals, Flexxaire will not knowingly provide support to, contribute to, assist with, or facilitate armed conflict in the DRC
Flexxaire will not knowingly provide any direct or indirect support to non-state armed groups or security forces that illegally control or tax mine sites, transport routes, trade points, or any upstream actors in the supply chain.
Flexxaire will follow due diligence procedures relating to Conflict Minerals which are consistent with a nationally or internationally recognized due diligence framework which may include the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
Suppliers are encouraged to procure materials through conflict-free sources and, when reasonably feasible, through validated smelters. Flexxaire does not want to prevent its suppliers from sourcing responsibly from legitimate mines located within the DRC as doing so could be detrimental to the local economies and populations.
Where possible, Flexxaire will incorporate the principles of responsible sourcing of Conflict Minerals into our contract terms with suppliers and will work with our suppliers to create awareness of these issues within our supply base. We will make our position statement available to our suppliers and expect them to adopt similar positions or policies with respect to their own supply chains.
Flexxaire is not required by law to report Conflict Minerals and their sources contained in its products, however, Flexxaire has numerous customers that are required by law to report them. Flexxaire encourages its suppliers that manufacture components, parts, or products containing Conflict Minerals to procure those materials from conflict-free sources. We expect our suppliers to adopt, implement and communicate to sub-suppliers their positions and policies regarding Conflict Minerals, and where possible, require their down-stream suppliers to adopt and implement similar positions and policies. Flexxaire’s suppliers are expected to work with sub-suppliers to trace conflict materials at least to the smelter level and encourage the use of a standard reporting process (e.g. the Conflict Minerals Reporting Template). Suppliers are encouraged to support industry efforts to enhance traceability of Conflict Minerals and responsible practices in their global supply chains.
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