The Dodd-Frank Wall Street Reform and Consumer Protection Act, passed into law in July 2010, contains language requiring publicly listed U.S. companies to report to the Securities and Exchange Commission (SEC) on the origins of “Conflict Minerals” (Gold, Tin, Tungsten and “Tantalum”) used in their products, and demonstrate due diligence to avoid sourcing these materials from the Democratic Republic of the Congo (DRC) or “adjoining countries”, including Angola, Burundi, the Central African Republic, Rwanda, South Sudan, Tanzania, Uganda, or Zambia. The goal of this act is to eliminate direct or indirect funding of armed groups engaged in violent acts and human rights abuses against the populations of these regions.
Clearfield does not directly source any of these minerals for use in our products. However, these minerals are commonly included in many components, subassemblies, and materials used in the electronics and cable industries, including some sourced and used by Clearfield, and even though we and our suppliers are many tiers removed from the actual mining operations in these countries, Clearfield is still committed to the ideals of the Dodd-Frank regulations and avoiding the purchase of products that contain minerals from mines in this conflict region.
To meet our obligations, Clearfield has implemented this corporate policy statement regarding Conflict Minerals. This policy requires: