Conflict Minerals Policy
Conflict minerals refer to tantalum, tungsten, tin, and gold originated in the Democratic Republic of the Congo and its adjoining countries (“Covered Countries”). There are concerns that the conflict minerals fund armed forces of the Covered Countries causing many deaths of their own people and infringement of human rights in the course of mineral excavation such as forced labor and abuse of women and children. In response to these concerns, the United States Congress enacted the Dodd–Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). Section 1502 of the Dodd-Frank Act (“Conflict Minerals Rule”) requires manufacturing companies listed in U.S. stock exchange to disclose whether the products they manufacture or contract to manufacture contain conflict minerals.
As a responsible corporate citizen,
LiComm policy is to eliminate the use of conflict minerals contained in our products that directly or indirectly finance or benefit armed groups in the Covered Countries.
In support of our Conflict Minerals Policy, LiComm will:
• Implement procedures compliant with global standards that regulate conflict minerals and totally support activities of the Conflict Free Sourcing Initiative by CFSI and CFSI.
• Endeavor to trace the names and locations of all the smelters or refiners using conflict minerals including tantalum, tin, tungsten, and gold through use of the CFSI Conflict Minerals Reporting Template.
• Require our suppliers to submit the Form or otherwise verify in writing that all products supplied to LiComm do not contain conflict minerals from the Covered Countries that directly or indirectly finance or benefit armed groups in those Covered Countries.
• Direct our suppliers, whenever possible, to source conflict minerals from the smelters validated through EICC/GeSI Conflict-Free Smelter Program. (The list of conflict-free smelters is available here.)
• Establish a supply chain due diligence process for identifying the source of conflict minerals based on the OECD Due Diligence Guidance and when necessary, perform due diligence on suppliers’ source and chain of custody of conflict minerals.
• Disclose the use of conflict minerals in accordance with the Conflict Minerals Final Rule.
LiComm also requires our suppliers to familiarize themselves with the Conflict Minerals Rule and expects our suppliers to adhere to the Conflict Minerals Rule and LiComm Conflict Minerals Policy to ensure alignment throughout their own supply chain.
LiComm expects and will obligate our Suppliers to:
• Have a documented conflict mineral policy and procedures to ensure that all products supplied to LiComm do not contain conflict minerals from the Covered Countries that directly or indirectly finance or benefit armed groups in those Covered Countries.
• Identify through reasonable efforts all smelters that supply conflict minerals in their supply chain.
• Submit a complete Form containing conflict minerals information in a timely manner to LiComm.
• Correct promptly any risk identified in their supply chain.
Should LiComm come to know or have reason to suspect that a supplier is procuring conflicts minerals from a Covered Country that directly or indirectly finance or benefit armed groups in those Covered Countries, LiComm will notify such supplier in writing and give the supplier reasonable time to cure the non-compliance and submit documentation showing the non-use of such conflicts minerals. If the supplier does not cure or cannot provide proper documentation evidencing a change in the sourcing of conflicts minerals, or is found to have provided false records or information at any time,
LiComm may terminate its business with that supplier.
As a part of a commitment to corporate responsibility, LiComm will voluntarily contribute to prevent violation of human rights in the Covered Countries through collaboration with our customers and suppliers. We will continue our efforts to source conflict-free minerals to achieve a conflict-free supply chain.