AutomationDirect Conflict Mineral Due Diligence Plan
In July 2010, the U.S. Government signed the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). Section 1502 of the Dodd-Frank Act requires all US publicly traded companies to file disclosures and reports with the U.S. Securities and Exchange Commission related to the use of conflict minerals (tin, tantalum, tungsten and gold) in their products. More information on this topic is available at http://www.sec.gov/news/press/2012/2012-163.htm.
AutomationDirect is not covered under this rule but we desire to support our customers that do request information to carry out compliance and due diligence activities. AutomationDirect is not able to fill out individual surveys for our customers due to the volume and variety of the requests. However, we do have a plan to assist our customers as follows:
- AutomationDirect is requesting our suppliers to establish policies, due diligence frameworks, and management systems that are designed to accomplish a supply of products to AutomationDirect that are DRC conflict free (do not contain metals derived from columbite-tantalite (tantalum), cassiterite (tin), gold, wolframite (tungsten), or their derivatives such that they directly or indirectly finance or benefit armed groups through mining or mineral trading in the Democratic Republic of Congo or an adjoining country). While we have made these requests, we have not made it a requirement.
- AutomationDirect will use the industry standard CFSI's CMRT (version 4.10) and also provide an AutomationDirect product-specific template. We will survey all of our product suppliers to determine if conflict minerals are used in the products that we offer for sale. If yes, we will ask our suppliers if they know the country of origin for the conflict mineral(s) included in the product. The survey will be conducted at a product part number level. AutomationDirect currently has more than 100 global suppliers, over 20,000 products, and we are adding new products every year.
- We will also ask our suppliers to continue the process of surveying their suppliers to determine the use of conflict minerals and the country of origin.
- We will provide updated product information that has been collected by these supplier surveys on our website before January 31, 2017. Our customers will be able to access this information and use it in their compliance and due diligence activities.
- We plan to update the product information on our website each month as we launch new products throughout the year, and each fall (October/November) we will update our entire product list.
Again, please note AutomationDirect is not able to fill out individual surveys for our customers or to populate or upload this data to the various different reporting portals due to the volume and variety of these requests.
Automationdirect.com will use the industry standard CMRT 4.10 template for all reporting during the calendar year 2017. If a new form becomes available during the year we will evaluate this in the fall of 2017, and update accordingly. We will work with our suppliers to continuously improve our ability to satisfy customer requests for information.
The documents below are in Microsoft Excel format (.xlsx). A free viewer can be downloaded
from Microsoft at this link.