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Conflict Minerals Policy Statement

Introduction

On July 21, 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into law. The Dodd-Frank Act and related 2012 U.S. Securities and Exchange Commission rules require certain companies to disclose whether the products they manufacture or contract to manufacture contain Conflict Minerals necessary for the production or the functionality of the products that are sourced from mines in the Democratic Republic of Congo or adjoining countries. Conflict Minerals are tantalum, tin, tungsten and gold.

The Dodd-Frank Act set new guidelines for product manufacturers, many of whom are several layers of distribution removed from the source of the raw minerals in their products. Arcadia distributes a broad line of products that are manufactured by hundreds of other companies located around the world.  Arcadia is committed to acting in a socially and environmentally responsible manner, to complying with the law, and to meeting its customer requirements.

Because of the complexity of many supply chains, especially those of broad-line distributors like Arcadia, and the lack of an established system for product manufacturers and distributors to track Conflict Minerals back to their source, the joint efforts over an extended period by many governments, industry groups, and companies will be required to make it possible to effectively trace Conflict Minerals back to their source.

Arcadia Commitment

  • Act in a responsible manner, consistent with the objectives of the Dodd-Frank Act relating to Conflict Minerals sourcing, by assisting, to whatever extent possible, manufacturers of the products we distribute.

  • Assist our suppliers in taking appropriate steps to investigate the sources of Conflict Minerals in the products they sell to Arcadia, if any.

  • Discontinue sourcing from any supplier of products determined to contain Conflict Minerals if Arcadia ascertains the product is not DRC Conflict Free and the supplier does not take reasonable steps to transition to DRC Conflict Free sources.

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Note:  Products are “DRC Conflict Free” if they contain only Conflict Minerals that did not originate in the DRC or an adjoining country, are from recycled or scrap sources, or have not benefited the armed groups identified as perpetrators of the abuses that are the subject of the Dodd-Frank Act.

Supplier Expectations

Arcadia has the following expectations of its suppliers:

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  • Suppliers should not sell any products to Arcadia that contain any Conflict Minerals that are not DRC Conflict Free;

  • Suppliers should develop Conflict Minerals policies and procedures that are designed to prevent Conflict Minerals that are not DRC Conflict Free from being included in the products sold to Arcadia;

  • Suppliers should source Conflict Minerals only from sources that are DRC
    Conflict Free;

  • Suppliers should communicate to their personnel and suppliers such policies, and require their suppliers to do the same;

  • Suppliers should put in place procedures for the traceability of Conflict Minerals;

  • Suppliers should use reasonable efforts to source Conflict Minerals from smelters and refiners validated as being DRC Conflict Free, and require their suppliers to do the same;

  • Suppliers should advise Arcadia of any determination that the supplier has a reasonable basis to believe that products it currently sells or has sold to Arcadia are not DRC Conflict Free;

  • Suppliers should maintain business records, available for review Arcadia, supporting the source of Conflict Minerals;

  • Suppliers should from time to time, at Arcadia's request, provide Arcadia with information concerning the origin of Conflict Minerals included in products sold to Arcadia, which Arcadia shall be entitled to use or disclose in satisfying any legal or regulatory requirements or in any customer or marketing communications, notwithstanding the terms of any confidentiality agreements that do not specifically reference this paragraph.

Compliance Enforcement

Consistent with its QMS (Quality Management System) procedures, and its myriad certifications to industry quality standards, Arcadia evaluates the performance of its suppliers on an ongoing basis.  Arcadia reserves the right to evaluate supplier performance with respect to compliance with this Policy.  Arcadia reserves the right to request additional information and documentation from its suppliers relating to compliance with this Policy.  Suppliers who are deemed not to be in compliance with this Policy shall be reviewed by Arcadia for future business.  In the event that a supplier is found to be substantially out of compliance with this Policy and is found to have been deficient in taking corrective steps to remedy such non-compliance, Arcadia reserves the right to take appropriate actions up to and including the discontinuance of ongoing purchases.  Nothing in this Policy is intended to grant any additional rights to an Arcadia supplier, or in any way modify or limit Arcadia's contractual or legal rights. 

Arcadia employees, customers, suppliers or other interested parties, may report concerns or alleged violations of this Policy. Such reports may be submitted:

  • In writing to Arcadia Components, LLC, Attn: Conflict Minerals, 455 White Pine Drive, Salt Lake City, UT 84123, USA;

  • Or via email at:    

  • Or via phone at:   +1 801/261-5300.
     

Reports may be submitted anonymously and will be kept confidential to the fullest extent practicable and allowed by law. Arcadia will not take any retaliatory action against any party who submits a report in good faith. Arcadia suppliers are encouraged to contact Arcadia via one of the above methods if they wish to seek guidance on the application of this Policy.

Reporting Mechanism
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