There has been increasing awareness that the mining of certain minerals may be financing armed groups engaged in violence, human rights violations and environmental degradation in the Democratic Republic of Congo ("DRC") or one of nine African nations that share a border with the DRC (the "DRC Region"). These minerals, known as “Conflict Minerals” include: columbite-tantalite (coltan) refined into tantalum, cassiterite refined into tin, wolframite refined into tungsten and gold.
In order to curtail these social and environmental abuses the U.S. Securities & Exchange Commission (SEC) adopted Conflict Minerals provisions in Section 1502 of the Dodd- Frank Wall Street Reform and Consumer Protection Act of 2010. Among other things, this law directed the SEC to enact rules obligating US manufacturing companies to report whether the products they manufacture or contract to manufacture contain “Conflict Minerals” that are necessary to the functionality or production of those products.
Custom Comfort Medtek is committed to ethical practices and our objective is to have DRC Region conflict-free products and supply chain. We do not source directly from smelters or mines and recognize that the metals supply chain is complex and global. We are working closely with our own suppliers to understand, to the extent possible, the sources of the metals contained in the products they supply to us.
The process of tracing Conflict Minerals through a global supply chain is complicated and time-consuming, and some component suppliers or sub-suppliers may lack the resources to trace minerals all the way back to their source. Custom Comfort Medtek will endeavor in good faith to have its suppliers exercise reasonable due diligence to evaluate their respective supply chains for the information called for by the Conflict Minerals rule.
We expect our suppliers to adopt policies consistent with the SEC’s Conflict Minerals provisions and that they will put in practice steps to ensure that the minerals they include in their products are responsibly sourced. If we become aware of a supplier whose supply chain includes metals from a conflict source, we expect to take the appropriate action to remedy this situation in a timely manner, including reassessment of that supplier relationship. We expect our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
Custom Comfort Medtek is committed to complying with any requirements applicable to our Company under the Conflict Minerals rule; therefore, we will continue to evaluate our policies to ensure compliance with the SEC’s Conflict Minerals rule and make adjustments when necessary.