AutomationDirect Conflict Mineral Due Diligence Plan
Background
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 as the vast
majority of our customers either do not require conflict free supply or
are not required to report to the SEC.
- AutomationDirect will use the industry standard CFSI's CMRT (version 5.12)
and 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 plan to update the product information on our website each month as we launch new products throughout the year.
- We will provide updated product information that has been
collected by these supplier surveys on our website annually on or before
January 31st, 2020. Our customers will be able to access this
information and use it in their compliance and due diligence activities.
- If your company has a requirement for conflict free products, we
have provided a separate list by part number (Product Level
Information), so that your company can choose to purchase only products
from us that our suppliers have stated are conflict free.
Again, 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. Please upload the CMRT at the link provided.
Automationdirect.com will use the industry standard CMRT 5.12
template for all reporting during the calendar year 2019. If a new form
becomes available during the year we will evaluate this in the fall of
2020, and update for the following years report. We will work with our
suppliers to continuously improve our ability to satisfy customer
requests for information.
Current Disclosures
The documents below are in Microsoft Excel format (.xlsx). A free viewer can be downloaded
from Microsoft
at this link.
