The Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into U.S. federal law on July 21, 2010. Section 1502 of the Act defines the reporting obligations for companies that are publicly traded in the US and are governed by the Securities & Exchange Commission (SEC). Section 1502 requires companies that make products for which 3TG minerals (tantalum, tin, tungsten and gold) are necessary to the functionality or production of that product to assess their supply chains and publically report on the source of these minerals if they are sourced from the Democratic Republic of Congo (DRC) or adjoining country or if they are from recycled or scrap sources.
Although Barantec Inc. is not a publically traded company, and therefore not directly subject to this law, we are providing this declaration to our downstream customers to help them comply with any obligations relative to this law. Barantec’s Conflict Minerals Program is implemented with guidance obtained from the Final Rules of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
Barantec has completed a Reasonable Country of Origin Inquiry using a Conflict Minerals Reporting Template. This template provides a common means for the collection of sourcing information on conflict minerals to determine if conflict minerals contained in its products originated in the DRC or adjoining country or come from recycler or scrap suppliers.
This inquiry was reasonably designed and was conducted in good faith with an effort to obtain reliable representations indicating smelter or refiner facilities at which its conflict minerals were processed and that those conflict minerals did not originate in the DRC or adjoining country or come from recycler or scrap suppliers.
This document declares that all Barantec products contain one or more conflict minerals and that these minerals are necessary to the functionality of the products manufactured. Based upon our research this document declares that all conflict minerals used in Barantec products do not originate in the DRC or an adjoining country or come from recycler or scrap supplier.
This document certifies that all Barantec products are declared “DRC Conflict Free” since July, 2014.