SIERRA MONITOR CORPORATION CONFLICT MINERALS SOURCING POLICY
"Conflict minerals"1 originating from the Democratic Republic of the Congo (DRC) are sometimes mined and sold, "under the control of armed groups"2, to "finance conflict characterized by extreme levels of violence"3. Some of these minerals and the metals created from them (such as tantalum, tin, tungsten and gold) can make their way into the supply chains of the products used around the world, including those in the electronics industry. Sierra Monitor Corporation's suppliers acquire and use minerals from multiple sources worldwide. As part of Sierra Monitor Corporation’s commitment to corporate responsibility and respecting human rights in our own operations and in our global supply chain, it is Sierra Monitor Corporation’s goal to seek to use tantalum, tin, tungsten and gold in our products that are DRC conflict free while continuing to support responsible in-region mineral sourcing from the DRC and adjoining countries.
Sierra Monitor Corporation expects our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing conflict minerals are DRC conflict free. Sierra Monitor Corporation expects our suppliers to comply with the Electronic Industry Citizenship Coalition (EICC) Code of Conduct and conduct their business in alignment with Sierra Monitor Corporation's supply chain responsibility expectations.
Sierra Monitor relies on a third-party to evaluate suppliers and create the Report. The report is filed with the SEC, and is available directly from SEC.gov or from the SMC Investor Relations page.
In support of this policy, Sierra Monitor Corporation will:
- Exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and encourage our suppliers to do likewise with their suppliers.
- Collaborate with our suppliers and others on industry-wide solutions to enable products that are DRC conflict free.
- Commit to transparency in the implementation of this policy by making available reports on our progress to relevant stakeholders and the public.
To provide feedback on the content or execution of this policy, please contact Sierra Monitor Corporation via email at info@sierramonitor.com.
Adopted: May 2014
- Conflict minerals are columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives as defined in Dodd-Frank Act section 1502 and SEC Rule 13p-1 under the Securities Exchange Act of 1934
- Dodd-Frank Act Section 1502.
- DRC conflict free “means that a product does not contain conflict minerals necessary to the functionality or production of that product that directly or indirectly finance or benefit armed groups” as defined SEC Rule 13p-1 under the Securities Exchange Act of 1934.