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On August 22, 2012, the Securities and Exchange Commission (“SEC”) adopted a new rule and form, as mandated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), to require companies to publicly disclose their use of conflict minerals that originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (together with the DRC, “Covered Countries”). The new rule takes effect on November 13, 2012.
Section 1502 of the Dodd-Frank Act amends the Securities Exchange Act of 1934 to add Section 13(p), which directs the Commission to issue rules requiring certain companies to disclose their use of “conflict minerals” if those minerals are “necessary to the functionality or production of a product” manufactured by those companies or contracted by those companies to be manufactured. Under Section 1502, the term “conflict minerals” includes tantalum, tin, gold, or tungsten (3TGs). Congress enacted Section 1502 because of concerns that the exploitation and trade of conflict minerals by armed groups is helping to finance conflict in the DRC region and is contributing to an emergency humanitarian crisis.
The new rule applies to a company that uses any conflict minerals if:
Please reference - Conflict Materials – SEC Small Entity Compliance Guide
Microwave Filter Company, Inc. (MFC) is in the final stages of identifying the origin of all potential 3TG minerals used in the manufacture of our products. MFC does not directly source any materials directly from any smelters. As a result, MFC requires our suppliers to complete and return the EICC-GeSI public Conflict Minerals Reporting Template.
MFC has taken and will continue to do our due diligence to ensure that we and our suppliers are in compliance with supplying “DRC Conflict Free” materials. We will continue to monitor our suppliers to ensure that they are in compliance and and that they continue to comply with the conflicting mineral requirements. In the event that we discover a supplier is not compliance, we will take appropriate actions as is required.
Microwave Filter requires our suppliers to:
For more information about this policy, or for inquiries about specific products, please contact us at firstname.lastname@example.org. Many of our products do not use 3TG minerals and are already known to be “DRC conflict free”.