Custom Thermoelectric Conflict Minerals Policy

At Custom Thermoelectric, LLC, we recognize the responsibility to support our customers’ efforts to comply with the conflict minerals rules enacted under Section 15-2 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), which require public companies to annually disclose information to the U.S. Securities and Exchange Commission (the “SEC Rule”) about their use of certain minerals originating from the “Conflict Region.” ¹

Although Custom Thermoelectric is not directly subject to the SEC Rule, as it is not a reporting company, it supports the Dodd-Frank Act and the related SEC Rule that promote transparency and awareness regarding the use of “Conflict Minerals”. ²

Custom Thermoelectric does not directly purchase any Conflict Minerals from any source and does not knowingly procure any product containing Conflict Minerals from the Conflict Region. To the extent that Custom Thermoelectric’ value-added offering may include products that contain Conflict Minerals, Custom Thermoelectric is committed to working with its supply chain in order to identify ways to increase transparency regarding the origin and traceability of minerals contained in any products.

Custom Thermoelectric requires its suppliers to adopt similar policies and practices with respect to Conflict Minerals and to drive those efforts throughout their supply chain to ensure that such metals are being sourced only from (1) mines and smelters outside the Conflict Region, or (2) mines and smelters within the Conflict Region which have been certified by an independent third party as “conflict free.”

1 “Conflict Region” includes the Democratic Republic of the Congo, Angola, Burundi, the Central African Republic, The Republic of Congo, Uganda, Rwanda, South Sudan, Tanzania and Zambia.

2 “Conflict Minerals” include columbite-tantalite (tantalum), cassiterite (tin), gold, wolframite (tungsten) and any derivative of such minerals

PDF version