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Conflict Minerals

There has been increased awareness regarding the human rights violations in the mining of certain minerals from an area known as the “Conflict Region,” the Democratic Republic of the Congo (DRC), and surrounding countries.

As a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, publically traded companies have been chartered to undertake reasonable due diligence with their supply chain to determine if “conflict minerals” used in their manufactured products are being sourced from mines controlled by non-government or unlawful military groups within the Conflict Region. The definition of “Conflict Minerals” refers to tin, tantalum, tungsten and gold (3TG).

Espey Mfg. & Electronics Corp. (Espey) complies with industry guidelines, such as the joint Electronic Industry Citizen Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) by taking action to address responsible sourcing through the development of the Conflict-Free Smelter (CFS) program enabling companies to source conflict-free minerals.

Under these regulations, publicly traded companies must report annually on their use of conflict minerals (3TG) from the Conflict Region, using the industry accepted Conflict Minerals Reporting Template (CMRT) form. Espey customers require us to complete this form, and Espey remains diligent to continuously work with our supply chain to ensure internal compliance with our policies and compliance with SEC regulations.

Espey due diligence effort focuses on areas of tracing conflict minerals through issuing a series of letters, questionnaires and CMRT forms to our critical product related suppliers to ensure compliance. Espey is committed to ethical business conduct and the responsible sourcing of all materials through our approved supplier base.

Espey has developed and implemented a strategy to support the objectives of the U.S. regulations on the supply of Conflict Minerals.

Our commitment includes:

  • Espey has developed policies and procedures with the goal of preventing the use of conflict minerals or derivative metals necessary in the function or production of our product(s) that finance or benefit armed groups in the Conflict Region.
  • Espey will not knowingly procure specified minerals that originate from facilities in the Conflict Region that are not certified as conflict free.
  • Espey will continue to conduct a reasonable country of origin inquiry (RCOI) with our supply base as part of our due diligence process.  Accordingly, it is our intention to annually collect and evaluate supplier responses using the industry established and accepted CMRT form.
  • Espey’s expectation is suppliers whose products contain conflict minerals to establish policies, due diligence frameworks, and management systems consistent with the Organization for Economic Cooperation and Development (OECD) Guidance for a Responsible Supply Chain.

Espey believes in establishing and maintaining long-term relationships with our suppliers whenever possible. However, if we determine that a supplier is, or a reasonable risk exists that it may be violating this policy, then Espey shall require the supplier to commit to a suitable corrective action plan to source from a conflict free source. If suitable action is not taken, Espey shall pursue alternative sources for the product. Moreover, if Espey determines that any of the components in our products contain minerals from a mine or facility that is “non-conflict free,” Espey shall work towards transitioning to suppliers and material that is conflict free.

Espey intends to fully disclose and comply with all regulatory reporting requirements.

Respectfully,

Christopher D. Teel

Director, Strategic Sourcing & Quality

Espey Mfg. & Electronics Corp.

Click here for Conflict Minerals Report

Click here for Conflict Minerals Reporting Template  (CMRT)