We are committed to ensuring the products and services we source are provided under fair labor practices. As such, we work with our suppliers to limit the chance that our operations could contribute to the exploitation of global citizens.
Trafficking in Persons is the third largest criminal activity in the world, after illegal arms and drug sales. We are fully committed to the policy of the United States, as emphasized by Department of Defense statements, to vigorously attack this worldwide problem. Trafficking in Persons is a violation of human rights; it is cruel and demeaning; it is linked to organized crime; it undermines the Company's effectiveness to support the mission of our customers; and it is entirely incompatible with our Company's core values.
We will not tolerate employees or Subcontractor employees engaging in conduct which in any way will facilitate Trafficking in Persons.
The Company has a policy in place laying out managers' and employees' responsibilities in this area. Any concerns can be reported through the Ethics anonymous hotline (1-800-423-2010 or e-mail firstname.lastname@example.org).
The following are additional resources to report violations:
- Global Human Trafficking Hotline at: 1-844-888-FREE; and
- E-mail at: email@example.com
We are committed to ethical business conduct and the responsible sourcing of minerals through our global supply chain. In 2012, the Securities and Exchange Commission (SEC) issued final rules implementing the Conflict Minerals disclosure provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Under these rules, publicly traded companies must report annually on their use of conflict minerals (tantalum, tin, tungsten and gold) from the Democratic Republic of Congo ("DRC") or certain adjoining countries.
We work diligently with our global supply chain partners to ensure compliance with SEC regulations. The international supply chain for these minerals is complex and the tracing of them is challenging.
We are focusing our compliance efforts in the following areas:
- Tracing Conflict Minerals – We conduct a Reasonable Country of Origin Inquiry (RCOI) with our supply base using a coordinated, risk based approach. As part of this process, we collect and evaluate supplier responses to an industry established Conflict Minerals Reporting Template (CMRT).
- Validating Conflict-Free Sources – As part of our due diligence process, we follow the Organization for Economic Co-operation and Development (OECD) framework. As part of that framework, we work with multi-industry consortia to validate responsible sourcing practices. Engagement with a broad coalition of affected industries regarding the complexities of conflict minerals allows us to look at the associated issues more strategically and holistically than as an individual company.
- Reporting Results – We participate in the Responsible Minerals Initiative (formerly the Conflict Free Smelter Initiative) and expects our suppliers to utilize independent third party validated smelters. We also engage independent third parties, as appropriate, to review our conflict minerals approach and processes as well as our final report before it is filed with the SEC.
If you have specific questions or would like additional information, please email firstname.lastname@example.org