As many of our suppliers and customers have acknowledged publicly, the Dodd-Frank Act created a new expectation for product manufacturers which may be far removed from the source of the raw minerals in their products. EDMO distributes thousands of products that are manufactured by many other companies located around the world. EDMO is committed to acting in a socially and environmentally responsible manner, to complying with the law, to meeting its customer commitments and to supporting its customers' businesses. Because of the complexity of many supply chains, especially those of distributors like EDMO who provide product from numerous manufacturers the task of tracking product materials back to their original source is complex. A full accounting will only be possible when the joint efforts over an extended period by many governments, industry groups and companies will be required to make it possible to effectively trace Conflict Minerals back to their source.
This document sets forth the policy of EDMO Distributors, Inc. regarding Conflict Minerals.
As a responsible company, EDMO supports the goal of the Dodd-Frank Act of preventing armed groups in the Democratic Republic of Congo and adjoining countries from benefitting from the sourcing of Conflict Minerals from that region. As a distributor of thousands products by numerous companies located around the world, EDMO is invariably many levels away from the beginning of the supply chain for products it distributes.
This policy shows EDMO's commitment and its expectations for its suppliers regarding actions to address Conflict Minerals.
EDMO has the following expectations of its suppliers:
- Suppliers should not include in any products sold to EDMO any Conflict Minerals that are not DRC (Democratic Republic of Congo) Conflict Free;
- Suppliers should develop Conflict Minerals policies, due diligence frameworks, and management systems that are designed to prevent Conflict Minerals that are not DRC Conflict Free from being included in the products sold to EDMO; and
- EDMO's suppliers are expected to source Conflict Minerals only from sources that are DRC Conflict Free.
In doing so, suppliers will be expected to:
- Implement and communicate to their personnel and suppliers policies that are consistent with this policy, and require their direct and indirect suppliers to do the same;
- Put in place procedures for the traceability of Conflict Minerals, working with their direct and indirect suppliers as applicable;
- Use reasonable efforts to source Conflict Minerals from smelters and refiners validated as being DRC Conflict Free and require their direct and indirect suppliers to do the same;
- Advise EDMO of any determination that the supplier either has concluded or has a reasonable basis to believe that products it currently sells or has sold to EDMO are not DRC Conflict Free;
- From time to time, at EDMO's request, provide EDMO with information concerning the origin of Conflict Minerals included in products sold to EDMO, which EDMO shall be entitled to use or disclose in satisfying any legal or regulatory requirements or in any customer or marketing communications, notwithstanding the terms of any confidentiality agreements that do not specifically reference this paragraph; and
- Suppliers also are encouraged to support industry efforts to enhance traceability and responsible practices in Conflict Minerals supply chains.
Consequences of Supplier Non-Compliance
EDMO evaluates its relationships with its suppliers on an ongoing basis. EDMO reserves the right to evaluate to the extent to which a supplier has failed to reasonably comply with this policy. EDMO reserves the right to request additional documentation from its suppliers regarding the origin of any Conflict Minerals included in any products sold to EDMO. Suppliers who do not reasonably comply with this Policy shall be reviewed by EDMO for future business. Nothing in this Policy is intended in any way to grant any additional rights or expectations to an EDMO supplier or in any way modify or otherwise limit in any way any of EDMO's contractual or legal rights.
EDMO Fully understands the importance of this issue to its customers and it is committed to supply chain initiatives and overall corporate social responsibility and sustainability efforts that work towards a DRC Conflict Free supply chain. We encourage all of our suppliers to likewise support these efforts.