Conflict Minerals Policy


Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires publicly traded companies to report their use of “Conflict Minerals” (tin, tantalum, tungsten and gold) to the U.S. Securities and Exchange Commission. While Bay Associates Wire Technologies Corp. is not required to report to the SEC, we are actively conducting reasonable country of origin inquiries with our raw material suppliers to support our customers.

Many of our suppliers have stated their supply chains are “Conflict Free”; either their products do not contain the aforementioned metals or these metals do not originate from areas of conflict. Many suppliers are still determining smelter and mine of origin. A small number are still performing their supply chain investigation and have not provided a conclusive response. We will do our best to ensure we have significant statements from these suppliers.

BAWT uses the EICC CFSI Conflict Mineral Reporting Template as its primary method of performing supply chain investigation and reasonable country of origin inquiries.

Upon request, BAWT can provide statements on the presence and origin of “Conflict Minerals” in the supply chain of specific active finished good part numbers.


Response to company level questions found on the EICC CFSI Conflict Minerals Reporting Template:

Question

Response

Comment

A.  Do you have a policy in place that addresses conflict minerals sourcing?

Yes

B.  Is your conflict minerals sourcing policy publicly available on your website? (Note—If yes, the user shall specify the URL in the comment field.)

Yes

C.  Do you require your direct suppliers to be DRC conflict-free?

No

                     

D.  Do you require your direct suppliers to source from smelters validated by an independent private sector audit firm?

No

 

E.  Have you implemented due diligence measures for conflict-free sourcing?

Yes

BAWT requires smelters and mines of origin information from suppliers who state that their minerals or supply chain are conflict free.

F.  Do you collect conflict minerals due diligence information from your suppliers in conformance with the IPC-1755 Conflict Minerals Data Exchange standard [e.g., the CFSI Conflict Minerals Reporting Template]?

Yes

G.  Do you request smelter names from your suppliers?

Yes

 

H.  Do you review due diligence information received from your suppliers against your company’s expectations?

Yes

I.  Does your review process include corrective action management?

Yes

J.  Are you subject to the SEC Conflict Minerals rule?

No