Conflict Minerals Policy Statement
DODD-FRANK ACT:
As a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the Conflict Minerals rules that the U.S. Securities and Exchange Commission adopted, many companies must make public disclosures regarding whether “conflict minerals” used to manufacture their products originated in the Democratic Republic of Congo (“DRC”) or adjoining countries (collectively, together with the DRC, the “Covered Countries”). These “conflict minerals” consist of columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; often referred to collectively as 3TG.
These rules do not apply to Bradley, however, they apply to customers of Bradley, and those customers have asked Bradley to assist them in their efforts to comply with their SEC obligations.
OUR COMMITMENT TO RESPONSIBLE SOURCING:
Bradley is committed to supporting responsible sourcing of its materials from suppliers that share our values around human rights, ethics, and environmental responsibility.
Although Bradley does not purchase any of the conflict minerals (3TG) directly, we require our suppliers of materials which contain any conflict materials that are necessary to the functionality or production of said materials to only use DRC Conflict Free sources.
SUPPLIER EXPECTATIONS:
Bradley has set forth expectations of our suppliers in the “Bradley Supplier Manual” which is located at www.bradleycorp.com and requires suppliers to adhere to Bradley’s code of conduct, which includes the responsible sourcing of materials.
In order to support a conflict-free supply chain and comply with the applicable rules and regulations, Bradley requires that:
· Suppliers should not include in any products sold to Bradley any Conflict Minerals that are not DRC Conflict Free
· Suppliers should develop Conflict Minerals policies and management systems to ensure compliance with the aims and objectives of the U.S. legislation on the supply of Conflict Minerals
· Suppliers should perform due diligence on the sources of Conflict Minerals in their supply chains and make their findings available to us.
Suppliers of certain materials will be required to provide written confirmation of DRC Conflict Free status. Suppliers who do not reasonably comply with this policy will be reviewed for transition of business to sources that do comply.