Reasonable Country of Origin Inquiry
We are knowledgeable about the design, manufacture and composition of our commercial products, given our involvement in the original research and development
of, technology transfers relating to, and/or the testing and/or manufacture of, those products. As such, our supply chain and manufacturing teams and other subject matter experts within the Company, in consultation with their counterparts at
relevant suppliers, as appropriate, analyzed our commercial offerings on a product-by-product basis, including by examining product, material and component
lists, specifications and other supply chain and quality information and data, to identify whether any of the products that we manufactured (or contracted to manufacture) during calendar year 2023 contained (or were reasonably likely to contain) any
conflict minerals.
This team identified a small number of our products that contained (or were reasonably likely to contain) small amounts of conflict
minerals and confirmed that those conflict minerals were necessary conflict minerals. With this information, the team identified those direct suppliers that supplied materials containing (or reasonably likely to contain) necessary conflict minerals.
In accordance with the Rule, we initiated in good faith a reasonable country of origin inquiry, as described below, with those direct suppliers to determine whether the necessary conflict minerals in the materials supplied to us actually or may have
originated in the Covered Countries and/or actually or may have originated from recycled or scrap sources.
Due Diligence Measures
Design Framework
We utilize due diligence measures
for conflict minerals that are designed to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-Operation and Developments Due Diligence Guidance
for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum, Tungsten and the Supplement on Gold (Third Edition)(the OECD Due Diligence Guidance), specifically as
it relates to downstream companies, like us, that are far removed in the supply chain from smelters, refiners, mines or other points of origins of conflict minerals.
Diligence Program
In furtherance of our conflict
minerals due diligence, we performed the due diligence measures discussed below for 2023.
Company Management Systems
We took a number of steps described in the OECD Due Diligence Guidance to maintain strong company management systems.
As noted earlier, we have a Conflict Minerals Policy. We have assembled a cross-functional team comprised of representatives from senior management and the
procurement, supply chain, manufacturing, technical development and legal functions to implement, execute and refine our conflict minerals compliance process. This team is responsible for establishing and implementing our Conflict Minerals Policy
and the risk-based due diligence contemplated by that policy and legal requirements. Members of this team provide periodic updates to senior management regarding the status of due diligence and compliance efforts.
In general, we engage with suppliers through our supplier onboarding process, supplier quality agreements and quality systems assessments. Most of our
contracts with direct suppliers, however, have been in force for many years and historically did not require the supplier to provide us with information regarding the origin of conflict minerals. As we renew existing contracts, or enter into new
contracts, with suppliers for products, materials and components that may contain necessary conflict minerals, we seek to contractually require those suppliers to investigate upstream suppliers and sources and provide us information about the source
and chain of custody of necessary conflict minerals present in the products, materials and components they supply to us. In the absence of appropriate and effective flow-down provisions, we rely on the voluntary and timely cooperation of our direct
suppliers to provide the necessary information on the origin of necessary conflict minerals.