Section 1Conflict Minerals Disclosure
Item 1.01Conflict Minerals Disclosure and Report
Introduction
Our Business
IEC Electronics Corp. (“IEC Electronics,” “we,” “our,” “us,” or the “Company”) provides electronic manufacturing services to advanced technology companies that produce life-saving and mission critical products for the medical, industrial, aerospace and defense sectors. We specialize in delivering technical solutions for the custom manufacture of complex full system assemblies by providing on-site analytical testing laboratories, custom design and test engineering services combined with a broad array of manufacturing services encompassing electronics, interconnect solutions, and precision metalworking. We manufacture complex printed circuit boards and system- level assemblies, a wide array of cable and wire harness assemblies and precision metal components. We are headquartered in Newark, NY and also have operations in Rochester, NY and Albuquerque, NM. Conflict Minerals are necessary to the functionality or production of the products that we manufacture for our advance technology customers pursuant to the designs they provide to us.
Our Conflict Minerals Program
Our Conflict Minerals Program conforms to the Organisation for Economic Co-operation and Development (“OECD”) “Five- Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain” as reasonable within the context of our business and supply chain:
STEP 1: Establish strong company management systems. STEP 2: Identify and assess risk in the supply chain.
STEP 3: Design and implement a strategy to respond to identified risks.
STEP 4: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.
STEP 5: Report on supply chain due diligence.
Our Conflict Minerals Sourcing Policy
Our Conflict Minerals Sourcing Policy is available at https://www.iec-electronics.com/about/social-responsibility.
Our Supply Chain
As a provider of electronic manufacturing services, IEC Electronics is generally directed by our many customers to procure specific materials and components from a large number of specific manufacturers. In many cases, IEC Electronics purchases these materials and components from approved distributors and not directly from manufacturers. Due to this supply chain design, IEC Electronics has no direct interaction with smelters/refiners and no direct influence on smelter/refiner selection.
Reasonable Country of Origin Inquiry
IEC Electronics conducted a reasonable country of origin inquiry (“RCOI”) in good faith and in accordance with an internationally recognized framework. The RCOI included engaging a third-party vendor to assist in supplier data collection, management, and aggregation. As a result of the RCOI, IEC Electronics was unable to definitively determine if the conflict minerals used in the production of applicable products benefited armed groups in the Covered Countries.
The Conflict Minerals Report for the calendar year ended December 31, 2020 filed herewith as Exhibit 1.01, is available at https://www.iec-electronics.com/about/social-responsibility.
Item 1.02Exhibit
A copy of the Conflict Minerals Report for the year end December 31, 2020 is filed herewith as Exhibit 1.01.