In 2012, the U.S. Securities and Exchange Commission (SEC) adopted a rule to effect reporting and disclosure for “conflict minerals,” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The rule requires manufacturers who are U.S SEC filers to disclose whether the products they manufacture or contract to manufacture contain “conflict minerals” that are “necessary to the functionality or production” of those products.
As a UK company Odstock Medical Limited (OML) is not required to make a report, however it is recognised that our customers may be seeking reassurance about compliance with the requirements of the rule. OML is committed to instituting procedures to conduct the necessary diligence to allow US customers to comply with the final rule.
Conflict minerals refer to tin, tantalum, tungsten and gold (commonly referred to as “3TG”), regardless of where they are sourced, processed or sold. The final rule is intended in part to bring greater supply chain transparency to the use of such minerals originating from the Democratic Republic of Congo and adjoining countries in an effort to help end the violent conflict which has been financed, in part, by the exploitation and trade of conflict minerals.
Tin, tungsten, tantalum and gold are essential in the manufacture of a variety of electronic and medical devices, including some of OML’s products.
OML sources from numerous reputable suppliers who like OML are not subject to SEC regulations. Therefore, OML needs to rely on the cooperation of its suppliers in the implementation of this policy and in enabling OML to meet customers’ disclosure and reporting obligations. OML expects its suppliers to undertake reasonable due diligence within their supply chains to determine the origin of the conflict minerals contained in materials and products they supply to OML. Further, we expect our suppliers to source conflict minerals used in our supply chain responsibly in an effort to help end the violent conflict in the DRC.
Specific actions
OML aim to have all components for devices sourced from reputable suppliers who recognise and have adherence of the Conflict Minerals requirements.
OML is developing a supplier Code of Conduct which will incorporate a clause confirming agreement to and adherence of the Conflict Minerals requirements.
Suppliers and other external parties are encouraged to contact OML if they wish to report concerns.
Signed
Calum Grant-Wood
Managing Director