Telit Cinterion Group Conflict Minerals Policy
Updated September 2023
To contact the Designated Officers referred to in this Policy, you can send an e-mail to firstname.lastname@example.org.
1. POLICY STATEMENT
The Telit Cinterion group (“Telit Cinteiron”, “we”, “us” and “our”) fully supports efforts to eliminate the use of tantalum, tin, tungsten and gold (known as 3TG) emanating from mining operations in the Democratic Republic of Congo (the “DRC“) and adjoining countries, or from other conflict-affected and high-risk areas (“Conflict Minerals“). The proceeds from the supply of Conflict Minerals have been linked to financing armed groups and criminals, resulting in armed conflict, violence and other serious violations of human rights.
In 2010, the United States Congress enacted the Dodd–Frank Wall Street Reform and Consumer Protection Act in response to these concerns. This legislation requires certain public companies to provide disclosures about the use of 3TG emanating from the DRC and adjoining countries to make transparent the financial interests that support armed groups in this region.
In 2017, the EU Conflict Minerals Regulations was enacted. It requires EU importers of 3TG need to comply with, and report on, supply chain due diligence obligations if the minerals originate, or potentially originate, from conflict-affected and high-risk areas. Unlike the US legislation, it is not limited to 3TG from specific geographical locations.
Although the US and EU legislation does not directly apply to Telit Cinterion, Telit Cinterion understands the importance of managing its own supply chain in order to play its part in the responsible sourcing of Conflict Minerals.
Telit Cinterion employs reasonable endeavors to obtain conflict-free 3TG. Since Telit Cinterion’s suppliers may acquire and use 3TG from multiple sources worldwide, Telit Cinteion is likely to be many levels away from the beginning of the supply chain for the components used in the products it manufacturers or contracts to manufacture. Telit Cinterion expects its suppliers to have their own policies in place and to take due diligence measures that will enable Telit Cinterion to be reasonably assured that products and component supplied to it containing 3TG are conflict free.
2. TELIT CINTERION’S COMMITMENTS
In support of these policies, Telit Cinterion will:
- exercise due diligence with relevant suppliers and encourage its suppliers to do likewise with their suppliers.
- expect its suppliers to cooperate in providing due diligence information to confirm the 3TG in its supply chain are conflict free;
- collaborate with its suppliers and others on industry-wide solutions to enable products that are conflict free; and
- not continue to source any product from a supplier that contains 3TG if Telit Cinterion is unable to determines the 3TG is not conflict free and the supplier fails to implement reasonable steps to transition to conflict free sources.
Telit Cinterion expects its suppliers to:
- use reasonable endeavors to source 3TG only from sources that are conflict free;
- undertake reasonable due diligence within their supply chain to determine the origin of 3TG
- develop Conflict Minerals policies and management systems that are designed to prevent Conflict Minerals from being included in the products sold to Telit Cinterion; and
- comply with information requests on the source and origin of 3TG in the parts, components or materials provided to Telit Cinterion.
3. REPORTING BREACHES
If anyone working for or on behalf of Telit Cinterion becomes aware of the souring or use, or potential sourcing or use, of Conflict Minerals by Telit Cinterion, or any others breaches or potential breaches of this policy, they should report such violations to Telit Cinterion’s Designated Officers as soon as possible at: email@example.com.
Telit’s Designated Officers are:
- Telit Cinterion’s Chief Legal Officer; and
- The Chairman of Telit Cinterion’s Audit Committee.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith any suspicions relating to Conflict Minerals. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern.
This policy does not form part of any employee’s contract of employment, and we may amend it at any time. Breach of this policy may result in disciplinary action up to and including dismissal.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
- Training on this policy, and on the risk our business faces from Conflict Minerals in its supply chains, will be provided for all individuals who work for us and are responsible for procurement or supply of goods that may contain 3TG.
- This policy must be communicated to all suppliers who supply us with goods that may contain 3TG.
5. BREACHES OF THIS POLICY
- Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
- We may terminate our relationship with any supplier who does not meet the requirements of this policy, in particularly the expectations on suppliers set out in section 2.