Child Check-Mate Conflict Materials Policy
Conflict Minerals Policy
Child Check-Mate System, Inc.
Introduction
Child Check-Mate System, Inc. (CCM) strives to be a good corporate citizen and is committed to ensuring the health, safety and protection of all stakeholders. Managing CCM’s obligations in relation to Conflict Minerals is an important part of this corporate responsibility.
Background
In recent years there has been increased concern that the exploitation and trade of certain minerals originating in the Democratic Republic of the Congo and surrounding countries are helping to finance armed conflict characterized by extreme levels of violence. Tin, tantalum, tungsten and gold are commonly referred to as "conflict minerals" regardless of their country of origin. As required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, the U.S. Securities & Exchange Commission ("SEC") has adopted a rule to bring greater supply chain transparency to the use of conflict minerals originating from the Democratic Republic of the Congo and surrounding countries. The SEC's Conflict Minerals Rule requires SEC registrants who manufacture or contract to manufacture products containing conflict minerals that are necessary to such products' functionality or production to disclose the origin and status of the conflict minerals.
CCM, like many companies in the electrical and electronic product industries, uses some of these minerals in the manufacturing of its products because they are required for the functional performance of the CCM’s products. Because CCM is not a publicly traded company, it is not directly subject to the Dodd-Frank Act and SEC regulations related to Conflict Minerals. However, many of CCM’s valued customers are publicly traded companies. These customers require CCM to comply with the disclosure requirements of the Dodd-Frank Act so as to assist them in certifying that they are in compliance with SEC regulations related to these minerals. Therefore CCM is committed to identifying which Child Check-Mate products are impacted and targeting our efforts accordingly. Working with our suppliers to ensure that any Conflict Minerals contained in the products and materials supplied to CCM originate from Conflict Free sources. In addition, we are committed to engaging with our customers regarding their disclosure obligations.
Measures
In working towards these commitments, we have taken a number of steps to establish a “Conflict Minerals Compliance Procedure” that includes but is not limited to:
- Engaging with suppliers and requesting that they respond in a timely manner to our requests for evidence of compliance. The suppliers’ willingness to comply with this initiative will be a factor in CCM’s sourcing decisions
- Encouraging CCM’s suppliers to engage with their own upstream suppliers and supply chain to determine the source and chain of custody of any products containing conflict minerals supplied to Child Check-Mate;
- Procuring alternative products from those products and materials containing Conflict Minerals directly from Conflict Mines
- Updating the Child Check-Mate Supplier Code of Conduct and our purchasing terms and conditions to reflect this policy.
- Regular requests for (e.g. annually) suppliers to provide CCM assurances that they are following CCM’s Supplier Code of Conduct (including CCM’s Conflict Minerals Policy).
CCM’s Conflict Minerals Policy may be updated at CCM’s sole discretion without notice. A copy of this policy is available upon request from CCM.
Conflict Minerals Compliance Procedure
- On a regular basis (e.g. annually) CCM will request that suppliers confirm, in writing, understanding and compliance with CCM’s Supplier Code of Conduct (including CCM’s Conflict Minerals Policy).
- Reporting Document to be filled up by CCM suppliers must comply with IPC-1755
- The interval for requesting confirmation shall be specific to individual suppliers as CCM procures from various suppliers at different intervals (e.g. some product are only procured every several years).
- CCM will allow suppliers a reasonable time to review and return the Supplier Code of Conduct.
- Suppliers’ failure to review and accept or confirm CCM’s Supplier Code of Conduct shall inform CCM’s procurement practices and may result in a reduction or cessation of business with nonconforming suppliers.
