CONFLICT MINERALS POLICY
As a socially responsible company, Bharat Precision Industries has concern for the well-being of people and communities. We conduct business fairly and ethically, respect human rights, comply with laws and regulations, and follow a rigorous Code of Conduct.
Bharat Precision Industries supports the efforts of human rights organizations to end violence and atrocities in Central Africa (the Democratic Republic of Congo (DRC) and nine adjoining countries: Republic of Congo, Central Africa Republic, South Sudan, Zambia, Angola, Tanzania, Burundi, Rwanda and Uganda).
It has been widely reported that the major driver of this violence is the natural abundance of the minerals tin, tungsten, tantalum and gold, now referred to as "conflict minerals." Armed groups fight for control of mines in this region and use forced labor to mine and sell the minerals, which in turn funds ongoing violence.
In August 2012, the United States Securities and Exchange Commission (SEC) approved the final rule regarding the sourcing of conflict minerals as defined in the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502. Under this rule, publicly traded companies must report annually to the SEC the presence of "conflict minerals" originating from Central Africa in either the products they manufacture or contract to manufacture, or use in the production process.
We are committed to complying with this legislation and with the SEC Rule. Cooperation from our supply chains is necessary to provide source information, as we do not purchase these minerals directly from mines or smelters and, in many cases, purchase finished goods that are several layers removed from these sources. Accordingly, our suppliers are expected to commit to being or becoming DRC conflict-free and to providing the needed transparency of the supply chain so that components and materials supplied to us are DRC conflict-free. Suppliers are to adopt and implement policies, due diligence frameworks, and management systems, consistent with the Organization for Economic Cooperation and Development (OECD) Guidance, that aredesigned to accomplish this goal.
We request that our suppliers utilize the Electronic Industry Citizenship Coalition (EICC) and Global e-Sustainability Initiative (GeSI) Conflict Minerals Reporting Template and that our suppliers provide the template to their suppliers successively upstream in order to identify the relevant smelters and refiners. The results of this effort are to be compiled and reported to us through this same template.