In 2012, the U.S. Securities and Exchange Commission (SEC) adopted a final rule to implement reporting and disclosure related to Conflict Minerals, as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The rule requires manufacturers who are 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.
The SEC currently defines Conflict Minerals to include tin, tantalum, tungsten and gold (commonly referred to as 3TG), regardless of where they are sourced, processed or sold. The intent of these requirements is to further the goal of ending violent conflict in the Democratic Republic of the Congo (DRC) and in adjoining countries, which has been financed, in part, by the exploitation and trade of conflict minerals.
Acelity L.P. Inc. and its subsidiary companies have a long tradition of adhering to best practices in the conduct of their business. We are proud of our company’s ethical heritage and strive to protect that heritage through company Codes of Conduct which underscore a culture of high ethical standards, honesty, and commitment to conducting its business in accordance with applicable laws, rules and regulations.
Recognizing the effects of extracting, trading, handling and exporting minerals from conflict-affected and high-risk areas, and recognizing that we have the responsibility to respect human rights and not contribute to conflict, Acelity L.P. Inc. and its subsidiary companies are committed to supporting the aims and objectives of the U.S. legislation on the supply of Conflict Minerals. While the global supply chain for these minerals is complex and multi-tiered, we are committed to work toward limiting the use, within our supply chain where practicable, of Conflict Minerals that directly or indirectly finance or benefit armed groups in the DRC region. We are working towards:
Developing a reasonable due diligence framework in accordance with the international Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance.
Strengthening due diligence capabilities and processes to identify the use of 3TG in our supply chain.
Taking steps to conduct reasonable country of origin inquiries of our suppliers for 3TG minerals used in our product portfolio.
Engaging, as may be required, independent auditors to conduct an audit of our Conflict Minerals approach and processes.
Encouraging, as appropriate, our suppliers to make similar commitments and take similar measures.
Requiring suppliers, when appropriate, to provide us with certification to the country of origin and source of the materials used in the products provided to our company, or that they provide us evidence that the materials they supply us with are from smelters that are on the Conflict-Free Smelters list.
Acelity L.P. Inc. must rely on the cooperation of its suppliers in the implementation of and adherence to this Statement in order to meet its SEC reporting obligations. We expect our suppliers to provide timely responses to our inquiries, assist with contacting second tier suppliers, if the sources of minerals are unknown, and engage in consistent communications with us about their sourcing efforts.
If a supplier is found to not be in compliance with these expectations, the supplier is required to develop, implement and document plans to meet expectations in a timely manner. If the non-compliance cannot be resolved, we reserve the right to terminate the relationship with the supplier.
This Statement will be reviewed and updated as needed.