Conflict Minerals Policy Statement

In August 2012, the U.S. Securities and Exchange Commission (SEC) adopted final rules implementing Section 1502 of the Dodd- Frank Wall Street Reform and Consumer Protection Act (the "Conflict Minerals Rule"). Under these rules, publicly-traded companies must annually report to the SEC whether the products they manufacture or contract to manufacture contain conflict minerals originating from the Democratic Republic of the Congo (DRC) or adjoining countries.

Revenue from the mining and transport of these conflict minerals is believed to be financing or benefiting groups that are responsible for human rights violations. "Conflict minerals" refers to columbite-tantalite (coltan), cassiterite, wolframite and gold, and their derivatives tantalum, tin and tungsten, without regard to the location or origin of the minerals or derivative metals.

While Altec AIR is not a public company listed on a United States stock exchange, Altec AIR does business with U.S. public companies and supports its clients' efforts to conduct annual Reasonable Country of Origin Inquiry (RCOI) and due diligence filings.

Altec AIR supports industry-wide efforts to identify, reduce and hopefully eliminate the use of conflict minerals originating in the DRC and adjoining countries that are financing or benefiting groups committing human rights violations. In furtherance of this goal, Altec AIR leverages the Responsible Minerals Initiative (RMI) Conflict Minerals Reporting Template (CMRT) to gather and exchange supply chain information.

Altec AIR is also tracking emerging laws and industry practices concerning conflict mineral reporting. Altec AIR is committed to complying with any applicable requirements under the conflict minerals rule and has implemented a due diligence process that aligns with the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) to meet its obligations under the legislation.

Suppliers to Altec AIR are expected to establish their own conflict minerals policies, due diligence frame-works and management systems that align with RMI and OECD guidance. Suppliers' programs should be designed to prevent conflict minerals from being included in the products sold to Altec AIR. In the event Altec AIR determines that a supplier has failed to develop and implement reasonable steps to comply with this policy, Altec AIR reserves the right to take appropriate actions, which may include discontinuing the business relationship with the supplier.


Chris Foster
Managing Director, Altec AIR

View or Download the Conflict Minerals Policy Statement here.

Download the Altec AIR Conflict Minerals Report here.