January 10, 2016
Re: Humanetics’ policy and information availability regarding Conflict Minerals (Metals)
Many industries, including the electronics industry, utilize the metals of tin, tantalum, tungsten, and gold. These metals are derived from minerals that are mined throughout the world, including The Democratic Republic of Congo (DRC). Known to operate in the DRC are mines under the rule of non-government military groups or unlawful military factions.
“Conflict minerals,” as defined in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, are Columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives; or any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.
Metals derived from these minerals are tin, tantalum, tungsten, and gold. Humanetics, along with industry groups including the Electronics Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI), is taking appropriate measures to improve information availability to allow verification that these metals are sourced from “conflict-free” sources.
Humanetics’ policy explicitly prohibits suppliers from sourcing metals either known to be derived from conflict regions or designated as NOT DRC Conflict-Free. Due to the complexity of this issue, Humanetics is working with its supply chain in gathering the necessary information to demonstrate reasonable due diligence in verifying all sourced metals are derived from conflict-free mines and can be considered DRC Conflict-Free.
Humanetics is utilizing the EICC / GeSI Conflict Minerals Reporting Template (Template) to retrieve Conflict Minerals information from its supply chain, including disclosure of smelters and mines and their locations (countries). The EICC / GeSI established process requires that companies survey their suppliers, who in turn survey their suppliers, on down through the supply chain. Humanetics has recently initiated its request for Conflict Minerals data using the Template. We are allowing time for our supply chain partners to utilize the Template themselves and retrieve the necessary information from their respective supply chains.
‘Due diligence’ information required by the legislation will be made available by Humanetics for its customers and interested parties in a timeframe sufficient to allow the supply chain time to provide the information, and to meet all regulatory requirements as they may apply.
Joe Haynes Director of Corporate Quality
Humanetics is aware of the EU legislation controlling and restricting certain chemical elements under the REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) program.
REACH establishes specific duties and obligations on a business in the European Union (EU) which manufactures or imports a substance or article that includes a “substance of very high concern” (SVHC) in concentrations of more than 0.1% w/w. A substance which is listed on the “Authorization List” published by the European Chemicals Agency (ECHA) (Annex XIV of the REACH regulations) cannot be manufactured or imported in the EU after a fixed date unless the ECHA authorizes the use of the substance for a specific use or uses. As of January 15, 2018, there were 181 substances on the SVHC list and 43 substances on the Authorization List.
Article 33 of REACH requires supply chain participants to communicate the presence of Substances of Very High Concern (SVHC) over 0.1% by weight in their products. SVHC are identified on the Candidate List by the European Chemicals Agency (ECHA). New SVHC are added to the Candidate List at least two times annually.
The latest Candidate List of 174 SVHC can be found at the following URL: echa.europa.eu/candidate-list-table
We declare to the best of our knowledge and from the information given by our suppliers, our finished product do not contain any SVHC above the legal limit of 0.1% weight by weight.
We will continue to review the current and future additions to the “SVHC list” and will immediately notify our customers if and when a SVHC substance above the 0.1% level is discovered in our product.
January 15, 2018
Joe Haynes Quality Manager