Conflict Minerals Policy
There has been increased awareness regarding the human rights violations in the mining of certain minerals from an area known as the “Conflict Region”; the Democratic Republic of the Congo (DRC) and surrounding countries. In July 2010, the US Congress passed legislation requiring the US Securities and Exchange Commission (SEC) to adopt rules that all US publicly traded companies must disclose their use of Conflict Minerals. The SEC defines “Conflict Minerals” as gold, cassiterite, columbite-tantalite, wolframite, or their derivatives (specifically, tin, tantalum, and tungsten), or any other minerals or their derivatives determined by the US Secretary of State to be financing conflict in this region.
Hydrogenics is committed to avoiding the use of Conflict Minerals which directly or indirectly finance or benefit armed groups in the DRC or adjoining countries. Hydrogenics is also committed to complying with the reporting obligations required by the SEC, including the requirement that Hydrogenics conduct inquiries into the source of any Conflict Minerals included in its products.
Hydrogenics does not directly purchase or source the raw metals used in our products. For this reason, tracing materials back to their mine of origin is a complex endeavor but an important aspect of responsible sourcing.
We are in the process of developing and implementing a strategy to support the objectives of the U.S. regulations on the supply of Conflict Minerals. Our commitment includes:
- Developing policies and processes toward preventing the use of conflict minerals or derivative metals necessary to the functionality or production of our product (s) that finance or benefit armed groups in the Conflict Region.
- Not knowingly procure specified minerals that originate from facilities in the “Conflict Region” that are not certified as conflict free.
- Expecting suppliers whose products contain conflict minerals to establish policies, due diligence frame works, and management systems consistent with the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk-Areas that are designed to accomplish this goal, and requiring their suppliers to do the same.
Hydrogenics believes in establishing and maintaining long-term relationships with suppliers whenever possible. However, if we determine that any supplier is, or a reasonable risk exists that it may be, violating the policy, then we will require the supplier to commit to devise and undertake suitable corrective action to move to a conflict free source. If suitable action is not taken, we will look to alternative sources for the product. Hydrogenics efforts are not to ban procurement of minerals from the DRC and adjoining countries, but to assure procurement from responsible sources in the region. If we determine that any of the components of our products contain minerals from a mine or facility that is “non-conflict free”, we will work towards transitioning to products that are “conflict free”.
Telephone: Conflict Minerals Hotline: 905.361.4559