Kaertech is committed to conducting its worldwide business operations in a manner that complies with all applicable laws and regulations.

In respect of conflict minerals, Kaertech is committed to:

  • Inform direct suppliers about this Conflict Minerals Policy and its relationship to the company’s supplier code of conduct.
  • Work with its direct suppliers and sub-suppliers to understand the chain of custody for conflict minerals at least to the smelter or refiner level.
  • Take measures to source parts and components from its direct suppliers and sub-suppliers that are Democratic Republic of Congo (DRC) conflict-free. These measures may include adopting, disseminating and incorporating this policy in related purchase orders, contracts and other appropriate agreements with suppliers.
  • Encourage direct suppliers to track and improve their performance in sourcing minerals from their suppliers and sub-suppliers that are validated as being DRC conflict-free in accordance with a national or internationally recognized due diligence framework.

Conflict Minerals Policy

Kaertech will encourage its suppliers to:

  • Assist Kaertech in complying with the U.S. Securities and Exchange Commission (SEC) regulations and any other applicable regulations related to conflict minerals and provide all necessary declarations.
  • Undertake reasonable due diligence within their supply chain to determine the chain of custody and origin of the conflict minerals. Due diligence includes developing policies and management systems to use DRC conflict free minerals, including urging them to make these requirements apply to their direct suppliers and sub-tier suppliers and them to do the same with lower tiers of suppliers.
  • Take measures to purchase parts, components or materials from their direct suppliers and sub-tier suppliers who source minerals for their products from smelters or refiners validated as being conflict free in accordance with a nationally or internationally recognized due diligence framework.
  • Comply with information requests on the source and origin of conflict minerals in the parts, components or materials provided to Kaertech.
    Maintain records that document Kaertech compliance with applicable laws and regulations regarding conflicts minerals, including those related to conflicts minerals due diligence, for a period of no less than five years.

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