Conflict Minerals Statement
On August 22, 2012, the U.S. Securities and Exchange Commission (“SEC”) adopted a final rule (the “Rule”) to implement reporting and disclosure requirements related to “Conflict Minerals” as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”). The Rule requires manufacturers who file certain reports with the SEC to disclose whether the products they manufacture or contract to manufacture contain “conflict minerals necessary to the functionality or production” of these products that directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or specified adjoining countries. Many of these armed groups are responsible for human rights violations including acts of violence toward women and children.
“Conflict Minerals” include: columbite-tantalite (coltan) (i.e., tantalum), cassiterite (i.e., tin), gold, wolframite (i.e., tungsten) or their derivatives and could expand to include other minerals or their derivatives, as determined by the U.S. Secretary of State.
For humanitarian reasons Midway Products Group, Inc. fully supports the Section 1502 (“Section 1502”) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”), which aims to prevent the use of certain “Conflict Minerals” that directly or indirectly finance or benefit armed groups in The Democratic Republic of the Congo (DRC) or adjoining countries (as defined in the Act).
Midway Products Group, Inc. is committed to being proactive and will put fourth our best effort to avoid the use of Conflict Minerals. Midway Products Group, Inc. is also committed to complying with the reporting obligations required under Section 1502 of the Act, as well as the related rules and regulations issued by the U.S. Securities and Exchange Commission. Midway Products Group, Inc. will also comply with the requirement that we must conduct inquiries into the source of any Conflict Minerals included in its products.
Midway Products Group, Inc. suppliers and their downstream suppliers are required to acknowledge and comply with Midway Products Group, Inc. Code of Conduct, which includes requirements regarding Conflict Minerals.
- Support the aims and objectives of the U.S. legislation on the supply of “conflict minerals”
- Do not knowingly procure specified metals that originate from facilities in the “Conflict Region” that are not certified as “conflict free”
- Ensure compliance with these requirements and ask our suppliers to undertake reasonable due diligence with their supply chains to assure that specified metals are being sourced only from:
a. Mines and smelters outside the “Conflict Region” or,
b. Mines and smelters which have been certified by an independent third party as “conflict free” if sourced within the “Conflict Region”
This due diligence includes having our suppliers provide written evidence documenting that raw materials used to produce gold, tin, tantalum and tungsten, used in the materials to manufacture components and products supplied to Midway Products Group, Inc., originate from outside the “Conflict Region” or if they originate from within the “Conflict Region”, that the mines or smelters be certified as “conflict free” by an independent third party. The aim is to ensure that only “conflict free” materials and components are used in products that we procure.
If we discover the use of these minerals produced in facilities that are considered to be “non-conflict free”, in any material, parts or components we procure, we will take appropriate actions to transition product to be “conflict free”.
Midway Products Group, Inc. suppliers will be required to declare that all products supplied either:
- Do not contain Conflict Minerals that are necessary to their production or functionality or,
2. If they do contain these minerals, that they originate from non-conflict areas or from smelters that have been determined to be conflict mineral free
3. As of January 1, 2014, Suppliers will be required to submit an EICC-GeSI form annually or report via ipoint to Midway Products Group, Inc. by July 1st
4. Suppliers must document all steps taken to collect the required information in regards to Conflict Minerals and retain this information for no less than 3 (three) years
Midway Products Group, Inc. will eventually be audited on its due diligence efforts to collect the required information from our supply chains.
Midway Products Group, Inc. will assess its relationships with its suppliers on an ongoing basis to ensure continued compliance with this policy. Midway Products Group, Inc. reserves the right to request additional documentation from its suppliers and regarding the source of any Conflict Minerals included in its products.
We also reserve the right to conduct supplier audits to ensure that this policy is being followed. Suppliers who do not comply with these requirements shall be reviewed by Midway Products Group, Inc. supply chain organization for future business. In addition, if any human rights violations are brought to our attention, we ask our suppliers to investigate the matter and take necessary steps to correct the violations.
This document can be found at: