Section 1 – Conflict Minerals Disclosure
Item 1.01.
Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This disclosure for the calendar year ended December 31, 2024 is presented to comply with Rule
13p-1 under the Securities Exchange Act of 1934 (the “Rule”).
The Rule imposes certain
reporting obligations on Securities and Exchange Commission registrants whose manufactured
products contain conflict minerals which are necessary to the functionality or production of their
products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and
their derivatives, which are limited to tin, tantalum, and tungsten.
These requirements apply to
registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund
armed conflict.
If a registrant conducts a Reasonable Country of Origin Inquiry (“RCOI”) and determines that
the conflict minerals originated from sources other than the Democratic Republic of the Congo
or an adjoining country (the “Covered Countries”), or from recycled and scrap sources, they are
required only to submit a Form SD, which describes the RCOI.
Although a substantial percentage of the products we sell are purchased from third-party
suppliers as finished products, we manufacture or contract with third parties to manufacture a
portion of our product portfolio.
We determined that certain of those products contain Conflict
Minerals that are necessary to their functionality or production.
To determine if the Conflict Minerals in our manufactured and other covered products originated
from sources in the Covered Countries, we conducted a RCOI in good faith.
We surveyed all
known suppliers from whom we purchase materials containing the Conflict Minerals and
reviewed the available public websites of such known suppliers.
We also utilized the
Responsible Minerals Initiative’s Conflict Minerals Reporting Template
(CMRT) to obtain the
The responses to our inquiry and results of our review can be grouped into the two categories
identified below:
●
The supplier represented that its products do not contain Conflict Minerals from the
Covered Countries.
●
The supplier represented that its products contain Conflict Minerals from the Covered
Countries but they have implemented reasonable due diligence measures and
practices to ensure responsible sourcing (
e.g.
, participate in Conflict-Free Smelter
Program assessment protocols).
As a result of our RCOI, we have no reason to believe that our necessary Conflict Minerals (i)
may have originated in the Covered Countries or (ii) if they originated in the Covered Countries,
failed to meet conflict-free sourcing or the Conflict-Free Smelter Program assessment protocols.