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Conflict Minerals

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires publicly traded companies to report their use of “Conflict Minerals” (tin, tantalum, tungsten and gold) to the U.S. Securities and Exchange Commission. Daburn Electronics and Cable is not required to report to the SEC, however we actively conduct reasonable country of origin inquiries with our raw material suppliers to support our customers.

The majority of our suppliers have stated their supply chains are “Conflict Free”; either their products do not contain the aforementioned metals or these metals do not originate from areas of conflict. Some suppliers are still determining smelter and mine of origin.  A small number are still performing their supply chain investigation and have not provided a conclusive response.  We will do our best to ensure we have significant statements from these suppliers.  Daburn uses the CFSI Conflict Mineral Reporting Template to perform supply chain investigation and country of origin inquiries.

While Daburn cannot guarantee its entire supply chain is conflict free until all of its suppliers complete their investigations, we can ensure specified products are conflict free.


Daburn CMRT5.10 Template can be viewed or downloaded from this link.


The following is Daburn's response to the company level questions found on the CFSI Conflict Minerals Reporting Template:

 

Question Answer Comments 
A. Do you have a policy in place that addresses conflict minerals sourcing? (*) Yes  
B. Is your conflict minerals sourcing policy publicly available on your website? (Note – If yes, the user shall specify the URL in the comment field.) (*) Yes http://www.daburn.com/conflict-minerals-statement.aspx
C. Do you require your direct suppliers to be DRC conflict-free? (*) No  
D. Do you require your direct suppliers to source from smelters validated by an independent private sector audit firm? (*) No  
E. Have you implemented due diligence measures for conflict-free sourcing? (*) Yes Daburn requests smelter and mine of origin information from suppliers who state their metals or supply chain are conflict free. 
F. Do you collect conflict minerals due diligence information from your suppliers which is in conformance with the IPC-1755 Conflict Minerals Data Exchange standard [e.g., the CFSI Conflict Minerals Reporting Template]? (*) Yes  
G. Do you request smelter names from your suppliers? (*) Yes  
H. Do you review due diligence information received from your suppliers against your company’s expectations? (*) Yes Daburn reviews supplier forms for accuracy and completeness. 
I. Does your review process include corrective action management? (*) Yes Daburn requests additional information from suppliers if any CFSI template sections are incomplete.
J. Are you subject to the SEC Conflict Minerals rule? (*) No  



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