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Conflict Minerals Policy

Background

In 2010, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act requiring the Securities and Exchange Commission to issue rules specifically related to the use of “Conflict Minerals” within products manufactured by SEC registrants. Conflict Minerals are currently defined by US law as tin, tantalum, tungsten, and gold (also known as “3TG”). SEC registrants whose product contains 3TG conflict minerals must determine whether those minerals originated from the Democratic Republic of the Congo (DRC) or adjoining countries (DRC Region), and, if so, whether the 3TG is “conflict free.” The purpose of this provision is to further the humanitarian goal of ending the violent conflict in the DRC Region which has been partially funded by the exploitation and trade of 3TG originating in the DRC Region.

While Component Repair Technologies, Inc. (CRT) is not an SEC registrant, we do support customers who are required to work with their supply chain partners to take reasonable steps to ensure product sources remain “3TG Conflict Free.”

Suppliers

To this end, CRT requires suppliers of 3TG minerals that are used in the course of repairs performed on customer’s products to implement steps to support compliance with “3TG Conflict Free status.”

  • Direct suppliers of 3TG are required to provide CRT with a report, on an annual basis, to support CRT’s customers’ reporting requirements.
  • This report must identify the 3TG product they sell to CRT and the smelter that provided the original 3TG material.

The ultimate goal is the supply of 3TG material that is 3TG Conflict Free.