Responsible Minerals Sourcing Policy

Definition:

Responsible Mineral Sourcing is the policy of procuring raw minerals from a supply chain that respects human rights, protects human and environmental health, and combats forced labor, child labor, human trafficking, and slavery. Conflict minerals regulations cover the sourcing of tin, tungsten, tantalum, and gold (3TGs) from war-torn regions, particularly the Democratic Republic of the Congo and its surrounding countries, in compliance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Introduction:

TUFFLOK is dedicated to responsibly sourcing minerals. TUFFLOK seeks to avoid sourcing minerals that contribute to armed conflict or human rights abuses in Conflict-Affected and High-Risk Areas (“CAHRAs”), including the Democratic Republic of the Congo (“DRC”) and DRC-adjoining countries. TUFFLOK also seeks to avoid harming communities in CAHRAs through de facto embargoes of minerals sourced from those areas.

TUFFLOK deplores the violence and inhumane treatment in the DRC, adjoining countries, and other parts of the world. By adopting this policy and collaborating with our customers and suppliers, and through RMI (https://www.responsiblemineralsinitiative.org/), TUFFLOK is working with others to promote responsible business practices and foster peace and prosperity, which is consistent with AirGap International’s values.

Policy:

TUFFLOK is committed to responsible sourcing minerals, including 3TG and cobalt, using the OECD due diligence framework (https://www.oecd.org) by not supporting conflict or human rights abuses in the DRC region or other CAHRAs, while avoiding de facto embargoes. This position is consistent with TUFFLOK’s Human Rights Policy, Supplier Responsibility Code, and TUFFLOK’s respect for human rights in our operations and supply chains, as well as with the OECD Due Diligence Guidance and UN Guiding Principles.

TUFFLOK global suppliers are required per TUFFLOK’s Contract agreement templates and U.S. purchase order terms & conditions:

  • Supply materials to TUFFLOK that are “Conflict-Free.” That means minerals are from recycled or scrap sources or do not directly or indirectly finance armed groups through mining or mineral trading in the Democratic Republic of Congo.
  • This statement also applies to adjoining countries or other CAHRAs as determined by regulatory bodies and as guided by RMI (https://www.responsiblemineralsinitiative.org/).
  • We expect our suppliers to be transparent and responsibly source materials from the DRC, adjoining countries, and CAHRAs to avoid de facto embargoes.
  • Adopt policies and due diligence management systems consistent with OECD Guidance to identify, prevent, mitigate and, where appropriate, remediate risks associated with obtaining minerals, including 3TGs and cobalt. TUFFLOK expects suppliers to cooperate with TUFFLOK in evaluating compliance with these requirements.
  • Provide TUFFLOK information about the presence of requested minerals in their products, including 3TGs and cobalt, and data on the smelters and refiners in their respective supply chains. This information is consistent with the industry standard for Supply Chain Transparency provided in the Conflict Mineral Reporting Template (CMRT) or Cobalt Reporting Template (CRT) developed by RMI.
  • Procure, directly or indirectly, from smelters and refiners validated under the Responsible Minerals Assurance Process (RMAP) of RMI or other recognized audit and validation programs.
  • Suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation, remediation, or non-conformance with TUFFLOK’s policy.
  • Collaborate with others on cross-industry efforts, such as with RMI, to support responsible minerals sourcing, including ongoing education and training.
  • If you have any questions, please contact TUFFLOK for additional information by calling +1-714-990-2300.

TUFFLOK
Compliance Department
Placentia, California, USA