Effective Date: June 1, 2023
- Purpose and Scope
Sensorex is committed to responsible sourcing practices and the promotion of responsible supply chains. This Conflict Minerals Policy outlines our commitment to comply with applicable regulations and support the responsible sourcing of minerals.
- Policy Statement
Sensorex is committed to avoiding the use of conflict minerals sourced from regions associated with human rights abuses, environmental degradation, or unethical practices. Conflict minerals, as defined by the Dodd-Frank Wall Street Reform and Consumer Protection Act, include tantalum, tin, tungsten, and gold sourced from conflict-affected or high-risk areas.
- Compliance and Due Diligence
− Suppliers: We expect our suppliers to adhere to the same principles and undertake reasonable due diligence to ensure that minerals used in their products or components supplied to us are sourced from responsible and conflict-free sources.
− Supply Chain Transparency: We strive to maintain transparency within our supply chain regarding the origin of minerals. We work closely with our suppliers to gather information about the source of minerals used in our products or components.
− Reasonable Country of Origin Inquiry (RCOI): We conduct a reasonable country of origin inquiry to determine the origin of minerals in our supply chain. We expect our suppliers to cooperate in providing accurate and timely information about the origin of minerals used in their products.
− Responsible Minerals Initiative (RMI): We may participate in industry initiatives, such as the Responsible Minerals Initiative, to promote responsible mineral sourcing and support the development of responsible supply chains.
- Risk Mitigation
− Due Diligence Measures: We implement due diligence measures to identify and assess the risk of using conflict minerals in our supply chain. This may include engaging with our suppliers, conducting site visits, and requesting certifications or declarations regarding conflict mineral sourcing.
− Supplier Engagement: We work collaboratively with our suppliers to promote responsible sourcing practices. We encourage our suppliers to establish robust due diligence processes and cooperate in efforts to mitigate the risk of using conflict minerals.
- Reporting and Communication
− Reporting Obligations: We fulfill our reporting obligations as required by applicable regulations, such as submitting a Conflict Minerals Report to the Securities and Exchange Commission (SEC) if necessary.
− Communication: We communicate our commitment to responsible mineral sourcing to our stakeholders, including employees, customers, suppliers, and the public, through various channels such as our website, corporate communications, and supplier engagement initiatives.
- Continuous Improvement
We continuously review and improve our Conflict Minerals Policy and due diligence processes to align with evolving industry standards, best practices, and regulatory requirements. We remain committed to fostering responsible sourcing practices and minimizing the risk of using conflict minerals in our supply chain.
- Training and Awareness
We provide training and awareness programs to our employees and relevant stakeholders to promote understanding of conflict minerals issues, responsible sourcing practices, and their roles in ensuring compliance with our Conflict Minerals Policy.
We prohibit retaliation against any individual or entity that raises concerns, reports non-compliance, or participates in the implementation of this Conflict Minerals Policy. We encourage an open and transparent culture that fosters ethical behavior and responsible supply chain practices.
- Policy Review
This Conflict Minerals Policy will be reviewed periodically to ensure its effectiveness, alignment with industry standards, and compliance with applicable regulations. Any necessary updates will be communicated to relevant stakeholders.
Sensorex is committed to upholding this Conflict Minerals Policy and expects the same commitment from all employees, suppliers, and stakeholders involved in our supply chain.