Astronics

Conflict Minerals

Astronics Conflict Minerals Policy Statement

Astronics will comply with all applicable Conflict Minerals Regulations, including the US Securities and Exchange Commission’s Conflict Minerals Rule and the European Union’s Conflict Minerals Regulation.

Astronics’ Conflict Minerals Policy is to only use tin, tungsten, tantalum, or gold whose source can be traced to scrap/recycled materials or smelters and refiners that are conformant with the Responsible Minerals Initiative‘s (RMI) Responsible Minerals Assurance Process (RMAP). Astronics encourages the use of responsibly mined minerals from the Democratic Republic of the Congo and adjoining countries.

To ensure compliance with this policy, Astronics has put in place procedures that conform with the Five-Step Framework for Risk-Based Due Diligence as described in OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Astronics’ standard purchase order terms and conditions require our suppliers to adapt a conflict minerals policy similar to Astronics and to provide Astronics each year with an updated Conflict Minerals Reporting Template (CMRT), the industry-standard reporting form published by the RMI.

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 conflict mine sources. 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, which is a supplier survey tool to standardize the collection of information from the suppliers in our supply chain (www.conflictfreesmelter.org).

The following is the standard purchase order sourcing requirement issued by Astronics Corporation and its subsidiaries located in the United States:

32. CONFLICT MINERALS

  1. Seller must demonstrate that all gold, tin, tantalum or tungsten (or derivative thereof) (collectively referred to as “3TG”) in the products it sells to Astronics were sourced from RMI RMAP conformant smelters.
  2. As a public company, Astronics Corporation is required to comply with Section 1502 of the United States Dodd-Frank Wall Street Reform and Consumer Protection Act, and, among other things, such act requires that Astronics Corporation make certain disclosures related to the use of Conflict Minerals in filings it makes with the United States Securities and Exchange Commission. Seller will source and track the chain of custody of all 3TG that may be contained in any Goods in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or such other internationally recognized due diligence standard as Astronics Corporation may approve. Seller shall, if and whenever requested by Buyer or Astronics Corporation, provide Astronics Corporation with a declaration in the form of the EICC-GESI Conflict Minerals Reporting Template (“CMRT”) as adopted by EICC-GESI with respect to all Goods and any and all such other information and data related to the use of Conflict Minerals in Goods that Seller may reasonably request.
  3. Supplier will at all times be able to deliver to Astronics its current CMRT that has been generated through the surveying of its relevant direct suppliers within the previous 12 months using the most current version of the CMRT. The supplier is required to cascade this requirement down the supply chain to its suppliers and, in turn, require them to cascade the requirement to survey their suppliers using the CMRT at least once each year.
  4. If Buyer believes that a Good contains (or includes, makes use of or was made from a material, part or component that that contains) a 3TG whose purchase funded violence in the Covered Countries: (i) Buyer may, at its option, by providing notice thereof to Seller, suspend the Purchase Order as to such Good until Seller is able to confirm to the reasonable satisfaction of Buyer whether or not such Good contains any 3TG whose purchase funded violence in the Covered Countries; and (ii) if it is determined that such Good contains any 3TG whose purchase funded violence in the Covered Countries or if Seller is not able to confirm to the reasonable satisfaction of Buyer whether or not such Good contains any Conflict Mineral within 90 days after being requested to do so by Buyer, Buyer may, at its option, by providing notice thereof to Seller, terminate the Purchase Order as to such Good. Buyer shall have no liability or obligation with respect to any Good as to which the Purchase Order is terminated or suspended pursuant to this Section 32 (c).

Conflict Minerals Disclosure and Report

2021 Conflict Minerals Reporting Template