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Conflict Minerals Overview
The Securities and Exchange Commission (“SEC”) adopted final rules in August 2012 under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) to address the use of “conflict minerals.” These rules require public companies, such as Large Power, to conduct due diligence on their supply chains and disclose annually whether certain products contain conflict minerals originating from the “covered countries” that are essential to their production.
Definitions
“Covered countries” refers to the Democratic Republic of the Congo (the “DRC”) and its neighboring countries. “Conflict minerals” include tin (cassiterite), tungsten (wolframite), tantalum (columbite tantalite or coltan), gold and their derivatives, which originate from the covered countries.
Commitment to Ethical Sourcing
Large Power acknowledges the significant human rights violations associated with the extraction, trade, and transport of minerals from conflict regions. We are committed to sourcing materials responsibly, working only with suppliers who share our values of ethical practices. We strive to avoid contributing to conflict through our sourcing activities and are dedicated to upholding human rights.
Large Power does not tolerate corruption or unethical practices in our supplier relationships. We expect our suppliers to adhere to the same high standards. Suppliers are only retained after demonstrating compliance with our Code of Conduct and meeting other internal requirements, including those related to health, safety, and environmental responsibility. Furthermore, we conduct biennial audits of critical suppliers to ensure their ongoing compliance with our standards.
Large Power Conflict Minerals Position Statement
Large Power is dedicated to purchasing only those products and components that are free from conflict minerals sourced from areas that finance armed conflict. We expect our suppliers to comply with this commitment and support a conflict-free supply chain.
We are taking the following steps to comply with conflict minerals regulations:
- Identifying conflict minerals that are necessary for the production and functionality of our products.
- Performing supply chain due diligence in alignment with the Organization for Economic Cooperation and Development’s (OECD) Due Diligence Guidance.
- Expecting our direct suppliers to conduct similar due diligence on the sources of conflict minerals within their own supply chains and require their suppliers to do the same.
- Once a validated, conflict-free supply chain is established, we will ensure that our direct suppliers source minerals exclusively from this supply chain.
- If any direct supplier is found to supply us with conflict minerals that have not been sourced from a validated, conflict-free supply chain, or that fund conflict, we will take corrective action, including recommending alternative sourcing solutions or, if necessary, reassessing our relationship with the supplier.
We will continue to review and update our conflict minerals policy to ensure it remains effective and in alignment with evolving regulations.
