Conflict Minerals Statement

01Background

In the Democratic Republic of the Congo, its neighbouring states and other conflict-affected and high-risk areas, the extraction of certain raw materials can finance armed groups and be accompanied by severe human rights violations.

Regulation (EU) 2017/821 has required Union importers of tin, tantalum, tungsten, their ores and gold to carry out supply chain due diligence since 1 January 2021. In the United States, Section 1502 of the Dodd-Frank Act applies to publicly listed companies. Both frameworks build on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

02Materials concerned

Conflict minerals comprise tin (cassiterite), tantalum (coltan), tungsten (wolframite) and gold, referred to collectively as 3TG. We additionally follow developments regarding cobalt and mica, which the Responsible Minerals Initiative covers in its Extended Minerals Reporting Template.

Within our product range, solder wire and solder paste containing tin are the most directly affected items. Tantalum, tungsten and gold may be present in the electronic assemblies of soldering stations, desoldering equipment, measuring instruments and test devices.

03Our position in the supply chain

A1-ESD Equipment GmbH is a specialist distributor. We do not extract, smelt or refine raw materials. We do not import ores or metals within the meaning of Annex I to Regulation (EU) 2017/821 into the European Union and are therefore not a Union importer as defined by that regulation.

We source finished goods from manufacturers and authorised distribution partners. We have no direct influence over the selection of the smelters and refiners at the origin of that supply chain. Our contribution consists of passing requirements on to our suppliers and making their declarations available to our customers.

04Our principles

• We support the objectives of Regulation (EU) 2017/821 and of the OECD Due Diligence Guidance.
• We expect our suppliers to maintain their own conflict minerals policy and to exercise due diligence along their supply chains.
• We give preference to suppliers whose supply chains rely exclusively on smelters and refiners assessed under the Responsible Minerals Assurance Process or an equivalent programme.
• We work towards ensuring that the products we distribute contain no raw materials that finance armed groups.
• A boycott of the regions concerned is expressly not our objective. Responsibly conducted, legal mining secures livelihoods there and contributes to stabilisation.
• Should further raw materials be classified as conflict minerals in future, we will apply this statement accordingly.

05Implementation towards suppliers

Our Supplier Code of Conduct binds our sources of supply to these principles. When onboarding new suppliers we ask about the status of their due diligence measures.

Where we receive substantiated indications of violations, we request a statement and demand remedial action within a reasonable period. If none is forthcoming, we terminate the business relationship.

06Information for our customers

We forward manufacturer declarations and completed Conflict Minerals Reporting Templates (CMRT) on request, to the extent that the respective manufacturer makes them available to us. Please state the article number or product designation concerned.

Please direct enquiries to compliance@fluidics-equipment.com.

07Scope and review

This statement applies to A1-ESD Equipment GmbH and to all sales channels operated by it. We review it at least annually and whenever circumstances require.