On August 22nd, 2012, the U.S. Securities and Exchange Commission (“SEC”) published regulations implementing Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act (“Act”) governing Conflict Minerals. The Act requires companies to perform due diligence on the source and chain of custody of Conflict Minerals contained in their products. As a family of companies subject to this regulation, having an affiliate that is a US issuer of securities governed by the SEC,CTC adopts this policy to guide the implementation and maintenance of its Conflict Minerals program.
1. CTC strives to have a Conflict Free supply chain, and is committed to sourcing products and materials from non-conflict sources;
2. CTC expects that its suppliers have due diligence processes in place to identify the source of the Conflict Minerals contained in their products, and that those sources do not support conflict and violations of human rights; 3. To further the benefits of Section 1502 and promote its intended purpose, CTC will work with suppliers with underdeveloped processes, providing information and guidance in an attempt to increase supply chain transparency throughout the world and into the DRC and surrounding region.
NOTE ON GOLD SALTS
Some confusion exists as to whether or not gold salts remain in scope for Conflict Minerals due diligence under the SEC regulations. To date, the SEC has not released any affirmative guidance that gold salts are exempt, and as such, CTC plating suppliers shall be expected to establish the source of the gold salts integrated into plating baths and applied to our products.