Company policy
Introduction
In August 2012, the United States Securities and Exchange Commission (“SEC”) issued its final rules regarding “Conflict Minerals” as defined in and required by section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act).
As a result, many companies are now focusing on whether their products contain Conflict Minerals and (if so) whether such Conflict Minerals come from the Democratic Republic of Congo or any of the adjoining countries named in the Act. The Conflict Minerals Rule requires publicly traded companies to report annually the presence of conflict minerals (Tin, Tungsten, Tantalum, and Gold, or “3TG”).
Commitment
Helipebs Controls Ltd. recognises our corporate responsibility in ensuring the health, safety and protection of people who interact with our products and business, and we require high social, environmental and human rights standards among our suppliers. Ensuring the exclusion of Conflict Minerals from our supply chain (as far as is reasonably practicable) is a part of this corporate responsibility.
Helipebs Controls Ltd. is committed to working towards the absolute exclusion of the use of conflict minerals that directly or indirectly finance conflict in the countries named in the Act.
Supply Chain
In line with this commitment, Helipebs Controls Ltd. requires all of its suppliers to provide evidence that they have exercised due diligence in ensuring the exclusion of Conflict Minerals from their supply chain. Evidence of such may take the form of:
- A completed conflict minerals declaration using the EICC/GeSI Conflict Minerals Reporting Template (CMRT) at the most current revision.
and/or
- A written statement assuring due diligence has been exercised and that no Conflict Minerals remain present in any of the supplied product.
It is Helipebs Controls Ltd’s expectation that its suppliers will adopt policies and procedures, with respect to conflict minerals, that will enable us to reasonably assure products supplied to us are “conflict-free”. We may reconsider our willingness to partner with suppliers that fail to comply with this policy.