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U.S. law requires U.S. publicly traded companies that manufacture products containing “Conflict Minerals” [1], which are “necessary to the functionality or production” [2] of their products, to report annually to the Securities and Exchange Commission.
The law was enacted to address concern that Conflict Minerals originating from the Democratic Republic of the Congo or adjoining countries (collectively, the “DRC”), are being sold by armed groups to “finance conflict characterized by extreme levels of violence." [3]
Affected companies are required to conduct Reasonable Country of Origin Inquiries (“RCOI”) and undertake due diligence, as necessary, to determine whether Conflict Minerals in its supply chain may have originated in the DRC, and if so, whether those minerals benefited armed groups in those countries.
E.A. Fischione Instruments, Inc. is not a publicly traded company and, therefore, not required to report annually to the Securities and Exchange Commission. However, it is a supplier to publicly traded companies and. therefore, Fischione Instruments supports the compliance obligations by being aware of relevant Conflict Minerals law and cooperating in the RCOI process.
Adopted: May 13, 2014
[1] Conflict Minerals are defined by Dodd-Frank Act section 1502 and SEC Final Rule 13P-1 under the Securities Exchange Act of 1934 as cassiterite, columbite-tantalite (coltan), and wolframite, or their derivatives specifically tin, tantalum, and tungsten, respectively, and gold.
[2] Securities Exchange Act Section 13(p).
[3] Dodd-Frank Act Section 1502.