ControlTek Tackles New Reporting Requirements for a Conflict Free Supply Chain


ControlTek has recently released our company’s response to new SEC reporting requirements for minerals classified as Conflict Minerals. These minerals can include tantalum, tin, tungsten and gold - many of the same minerals found in the manufacturing and assembly of printed circuit boards and electronics devices. The new requirements are effective for all publicly traded companies whose products contain these metals. While ControlTek itself is not a publicly traded company, many of our manufacturing partners are.

The new reporting requirements reflect governmental concerns about money obtained from either the mining or transportation of these minerals in areas that are currently involved in armed conflicts or human rights abuses. These areas include the Democratic Republic of Congo (DRC) and surrounding countries.

On the surface, these requirements merely state that publicly-traded companies must report to the SEC annually on (a) whether they utilize conflict minerals in products they manufacture, or (b) what their supply chain is doing to identify the country of origin for any conflict minerals and the determination of whether any minerals sourced from the DRC region are in fact conflict-free.

In practice, this reporting obligation is quite complicated, as it requires all parts, products, and materials supplied to ControlTek to also be designated as conflict-free. Our suppliers must establish their own policies and due diligence frameworks consistent with the OECD (Organization for Economic Cooperation and Development, an international economic organization dedicated to stimulating economic progress and world trade) Due Diligence Guidance Guidelines.

ControlTek does not purchase any of the affected minerals directly from smelters or mines; in fact, there are many supply chain layers between ControlTek and where these metals are sourced. However, as an organization we believe this is a problem that our entire supply chain must approach together to take the proper steps towards an effective solution that ensures those responsible for human rights violations do not gain from their actions.

While getting each level of our supply chain into alignment with these new policies will take some time, we will continue to do everything in our power to work towards final products that are conflict-free.

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