Overview on Conflict Minerals
The Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”) contains several specialized disclosure provisions. Specifically, Section 1502 of the Act requires annual disclosure as to whether any conflict minerals are necessary to the functionality or production of a product manufactured or contracted to be manufactured by U.S. companies originated in the Democratic Republic of the Congo or an adjoining country. Conflict minerals currently include cassiterite (tin), columbite-tantalite (coltan – source of tantalum), wolframite (tungsten) and gold. These minerals are commonly referred to as “3TG”.
The Act passed into law in July 2010, contains requirements that U.S. companies report to the Securities and Exchange Commission (“SEC”) on the origin of conflict minerals or their derivatives and show due diligence if conflict minerals are sourced from the DRC or an adjoining country. The SEC published regulations implementing Section 1502 on August 22, 2012. The current report required by the SEC was filed May 31, 2016 for the calendar year ending December 31, 2015.
Astronics Corporation’s Approach on Conflict Minerals
Astronics Corporation is in the process of determining the products potentially containing conflict minerals and determining the sources of those conflict minerals within our supply chain. Suppliers to Astronics Corporation are advised to develop policies toward preventing the use of conflict minerals or derivative metals from mines sourcing conflict. Suppliers should document their efforts to determine the source of any conflict minerals or their derivatives and be prepared to provide evidence of the origin of 3TG metals in products supplied to Astronics Corporation. Our suppliers are requested to seek and obtain certification through the EICC/GeSI Conflict Free Smelter (CFS) program; a supplier survey tool to standardize the collection of information from the suppliers in our supply chain (www.conflictfreesmelter.org).