TPSCo Responsible Sourcing Minerals Policy
Responsible Sourcing Minerals Policy (Conflict Minerals Policy)
TS Group has adopted a conflict minerals policy in order to ensure that it does not incorporate Conflict minerals (as defined below) into items manufactured at TS Group’s facilities. “Conflict minerals,” as defined in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, are Columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives. Metals derived from these minerals are tin, tantalum, tungsten, and gold (3TG). These metals are derived from minerals that are mined throughout the world, including the Democratic Republic of Congo (DRC) , adjoining countries, and high-risk areas (CAHRAs) (collectively the “Covered Countries”). Armed groups operating in the Covered Countries have controlled many of the region’s mines and/or transit routes and have engaged in armed conflict, as well as committed some of the world’s worst human rights violations. Products which do not contain necessary Conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries are considered “Conflict free”.
TS Group is committed to responsible sourcing of Conflict minerals throughout its supply chain and to continued compliance with the applicable SEC rules and regulations related to Conflict minerals. TS Group supports the position of the Global e-Sustainability Initiative (GeSI) and Responsible Business Alliance (RBA) to avoid the use of Conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries.
TS Group has established programs aligned with the internationally recognized OECD due diligence framework to regularly evaluate its supply chain and require its suppliers to do the same as it does not purchase any tungsten or tantalum directly from smelters, refiners, or mines, but rather is many steps removed in the supply chain from the mining of these necessary Conflict minerals. Suppliers are prohibited from supplying TS Group with materials known to be derived from the Covered Countries that have not been confirmed as “Conflict free” via a recognized and credible third party process such as the Conflict Free Sourcing Initiative’s Responsible Minerals Assurance Process (RMAP). Suppliers shall have in place policies and due diligence measures that will assure that products and components supplied to them containing Conflict minerals are Conflict free. In addition, TS Group requires its direct suppliers of items that include 3TG to submit completed Conflict minerals declarations using the RMI (www.responsiblemineralsinitiative.org) Conflict Minerals Reporting Template (CMRT). TS Group reserves the right to take appropriate actions to enforce its conflict minerals policy, including discontinuing purchases from suppliers that fail to comply with this policy.
On an annual basis, Tower discloses on Form SD (Specialized Disclosure Report) its compliance with Rule 13p-1 under the Securities Exchange Act of 1934, including its reporting and disclosure requirements related to Conflict Minerals.
In addition to the SEC rule regarding the conflict minerals reporting, Tower voluntarily performs due diligence on the sourcing of Cobalt and reports its findings through the Cobalt CRT on its website.
Please direct any question about the Tower policies to the Company’s Corporate Compliance Officer at firstname.lastname@example.org.