Conflict Minerals Sourcing Policy

Sterling-ES works with our vendor Moxa to maintain a longstanding policy of working proactively to ensure that the actions we take to manufacture and distribute products do not violate the laws or customs of the regions we do business in or impinge negatively on the rights of others.

With respect to the issue of “conflict minerals” it is Sterling-ES and Moxa’s policy to not knowingly purchase products, components, or materials that contain conflict minerals, and avoid contributing to conflict through sourcing practices. To provide reasonable assurance that this policy is complied with, Moxa is taking steps to ensure that the use of cassiterite (tin ore), wolframite (tungsten ore), coltan (tantalum ore), and gold, or their derivatives meets the United States enacted Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

We are taking due diligence measures and use the EICC-GeSI (Electronic Industry Citizenship Coalition – Global e-Sustainability Initiative) due diligence tools to communicate our policy to our direct suppliers. We request that all of our suppliers be DRC (Democratic Republic of the Congo) conflict-free and source from smelters validated as compliant to a CFS (Conflict-Free Smelter) protocol using the CFS Compliant Smelter List. We also require suppliers to provide a completed Conflict Minerals Reporting Template to provide reasonable assurance that the specified minerals are not being sourced from “Conflict Regions.”

It is important to note that our efforts are not intended to completely ban the procurement of minerals from the DRC and adjoining countries, but instead to provide reasonable assurance that the specified minerals are obtained from responsible sources in the region. We ask our suppliers to cooperate with us in our efforts to ensure that we only procure non-conflict minerals. Sterling-ES and Moxa encourage our suppliers to responsibly source non-conflict minerals and derivative metals from the DRC and neighboring countries in order to prevent an embargo and associated worsening of economic conditions and human suffering.

Sterling-ES and Moxa expect suppliers to:

  • source materials from DRC conflict-free resources.
  • comply with the Dodd-Frank Wall Street Reform and Consumer Protection Act and provide the “Conflict Mineral Reporting Template” and all necessary declarations.
  • establish their own due diligence program to ensure conflict-free supply chains.
  • ensure that all parts used to manufacture products supplied to Moxa originated from certified conflict-free smelters validated as compliant to the EICC CFS protocol, using the CFS Compliant Smelter List.

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