Conflict Minerals Policy



In 2010, Congress enacted the conflict minerals provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) to address the exploitation and trade of certain minerals which contribute to violence and human rights abuses in the Democratic Republic of the Congo (the “DRC”) and its neighboring countries. In 2012, the SEC adopted rules implementing the conflict minerals provisions of the Dodd-Frank Act (the “Conflict Minerals Rules”), which require public companies to disclose information annually about whether the products they manufacture or contract to manufacture for which Conflict Minerals are necessary to the functionality or production of those products contain Conflict Minerals that originated in any “Covered Countries,” and, if so, information about the source and chain of custody of those Conflict Minerals. The “Conflict Minerals” for the purposes of the Conflict Minerals Rules are gold, columbite-tantalite (coltan), cassiterite, and wolframite (including their derivatives, tantalum, tin and tungsten), and the U.S. Secretary of State may designate other minerals in the future. The “Covered Countries” for the purposes of the Conflict Minerals Rules are the DRC, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. We support efforts to further the humanitarian goal of ending violent conflict in the DRC and in surrounding countries, which we understand has been partially financed by the exploitation and trade of Conflict Minerals.

Our Policy

We support the Dodd-Frank Act’s goal of preventing armed groups in the Covered Countries from benefiting from the sourcing of Conflict Minerals from that region. We are committed to responsible sourcing of materials for our products, including the sourcing of Conflict Minerals, and we expect that our suppliers are likewise committed to responsible sourcing. We also support greater transparency with regard to the supply chain, in particular the sourcing of Conflict Minerals. Accordingly, we have adopted this Conflict Minerals Policy, and we expect that our suppliers will follow a similar policy and meet our expectations set forth below. As our supply chain is complex, tracing the minerals in our products to their source is a challenge and the manufacture our products is significantly removed from the mining, smelting and refining of Conflict Minerals, we are committed to working diligently with our suppliers to comply with applicable SEC regulations.

To do this, we are focused on three key activities:

  • Executing a phased approach with suppliers to support compliance with the SEC’s conflict mineral regulations (including conducting reasonable country of origin inquiries with the appropriate due diligence as necessary, as to the sourcing of the Conflict Minerals);
  • Working with our suppliers to seek conflict-free sourcing for these mineral; and
  • Filing the required report related to Conflict Minerals with the SEC.

Our Expectations for Suppliers

Accordingly, we have the following expectations of our suppliers to facilitate our compliance with the Conflict Minerals Rules:

  • Suppliers should develop policies, procedures, due diligence processes and management systems that are reasonably designed to provide for the sourcing of DRC Conflict Free products and materials and to provide transparency as to the source of any Conflict Minerals (“DRC Conflict Free” means that the product does not contain Conflict Minerals that directly or indirectly financed or benefitted armed groups in the Covered Countries);
  • Suppliers should not supply us with any products or other materials that directly or indirectly finance or benefit armed groups in the Covered Countries;
  • Suppliers are expected to take reasonable steps to identify the steps in the supply chain through which Conflict Minerals are introduced, and to undertake the due diligence efforts necessary to identify the smelter, refiner and/or mine from which Conflict Minerals originate, including requiring direct or indirect suppliers to our suppliers to cooperate in diligence efforts and to provide any information necessary to facilitate our compliance efforts with respect to the Conflict Minerals Rules; and
  • Suppliers should provide us with timely and accurate information regarding the presence and source of Conflict Minerals in our supply chain and the steps that have been undertaken to determine whether such products and materials are DRC Conflict Free, including whether the source has been verified by a recognized, independent third party.

We will evaluate our relationship with our suppliers on an ongoing basis, and we reserve the right to evaluate the extent to which a supplier complies with this Conflict Minerals Policy. Nothing in this Conflict Minerals Policy is intended to in any way grant any additional rights or expectations to any of our suppliers, or in any way modify or otherwise limit our contractual or legal rights.

Additional Information
Our employees, suppliers and other interested parties may contact us regarding this Conflict Minerals Policy at: Authentidate Holding Corp., Attention: Chief Financial Officer, Support