• | Adopted a Conflict Minerals Compliance Policy in 2013 governing the supply chain of Conflict Minerals from the Conflict Areas. |
• | Communicated DMC's Conflicts Mineral Compliance Policy to our employees and vendors. |
• | Created an internal Conflict Minerals Compliance Team to design and lead DMC's due diligence and risk mitigation efforts. |
• | Identified all vendors from which DMC purchased raw materials during 2014. |
• | Requested that each such vendor provide DMC information about the extent to which its products purchased by DMC did or did not include any Conflict Minerals. |
• | Obtained (as the preferred reporting format from each vendor) a completed Conflict Minerals Reporting Template, which was developed by the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative ("EICC/GeSI") |
• | Identified any vendor who, in its response to DMC, indicated that its product(s) may have contained Conflict Minerals from the Conflict Areas. |
• | One vendor disclosed that materials acquired from one of its suppliers included Conflict Minerals which originated from a Covered Country. |
• | As described below, verified that this supplier was listed as compliant with the Conflict-Free Smelter Program assessment protocols of the Conflict Free Sourcing Initiative and thus did meet the requirements for classification as a Conflict-Free Smelter. |
• | Products: certain liners and related materials containing tin used in the DynaEnergetics division. |
• | Facilities Used to Produce the Conflict Minerals/Efforts to Determine Mine or Location of Origin: Of the approximately twenty-five tin smelters that our vendors identified as being the source of these materials, approximately twenty-three are listed on the Conflict-Free Tin Smelter list published by the Conflict Free Sourcing Initiative. The two others were under audit by the Conflict Free Sourcing Initiative as part of the process to be added to that list. |
• | Country of Origin: Of the tin determined to originate from any Covered County, a majority of smelter intake was reported as having originated from Rwanda and the Katanga Province of the Democratic Republic of the Congo. |
• | Continuing efforts to increase the response rate from vendors; |
• | Expanding the implementation of conflict minerals assessment in the vendor approval process beyond those divisions which implemented the assessment in 2014; |
• | Evaluating joining the Conflict Free Sourcing Initiative or other third party due diligence initiatives; and |
• | Reviewing-and enhancing where we deem appropriate-the composition and training of the internal DMC group leading DMC’s conflict minerals compliance efforts. |