Conflict Minerals Sourcing Policy

The Dodd-Frank Wall Street Reform and Consumer Protection Act required the U.S. Securities and Exchange Commission (SEC) to adopt rules requiring SEC reporting companies (such as many of C-Flex customers) to file reports with the SEC disclosing their use of tin, tantalum, tungsten, and gold (“conflict minerals” or “3TG”) in products sold anywhere in the world. These requirements have been imposed because some of the conflict minerals originating in certain portions of Africa have been mined and sold under the control of armed groups. The SEC rules implementing these disclosure requirements provide that reporting companies that manufacture products (or contract with others to manufacture products) that contain 3TG must review their supply chains and gather and disclose information about the source and chain of custody of the 3TG in their products, with a focus on minerals that originate from the Democratic Republic of Congo (“DRC”) and adjoining countries.

In accordance with these legal requirements and as the overall commitment of  C-Flex Bearing Co., Inc. to responsible sourcing, C-Flex is working with its customers and suppliers to ensure transparency to the smelter/refining source for 3TG materials.  Furthermore, C-Flex does not use 3TG materials in its current standard product line.  We undertake efforts to promote responsible sourcing.  C-Flex does not support the direct or indirect funding of armed groups operating in the DRC or adjoining countries and is in support of responsible sourcing throughout the world.

Because of C-Flex’s position in the supply chain, it relies on suppliers for information. C-Flex expects its suppliers to respond to its requests for complete transparency about the sources of any 3TG materials used in supplier products and to conduct due diligence measures to ensure the information provided is accurate, up-to-date and complete. Our policy applies to all suppliers of products and materials to C-Flex Bearing Co., Inc. and to all C-Flex customers.

In accordance with this policy, C-Flex:

  1. Will exercise due diligence with relevant suppliers, 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 and encourage direct suppliers to do likewise with their suppliers.
  2. Expects suppliers to cooperate in providing due diligence information when requested to confirm the sources for all 3TG materials, if any, contained in C-Flex purchases.

C-Flex Bearing Co., Inc. will consider taking various progressive actions with respect to suppliers who do not make reasonable efforts to cooperate with C-Flex’s requests for information or requests to take corrective actions to enable C-Flex to identify smelters and refiners in its supply chains. These measures may include continuing business with the supplier as the supplier undertakes risk mitigation measures or temporarily suspending business with the supplier while the supplier pursues ongoing risk mitigation efforts. Ultimately, with respect to suppliers who have failed or refuse to make requested mitigation efforts or where mitigation appears unfeasible, these measures may include termination of the relationship.

Please contact C-Flex at cflex@c-flex.com to provide feedback to the execution or content of this policy.

For more information regarding CONFLICT FREE SOURCING, refer to the following links:

http://www.conflictfreesourcing.org

http://www.oecd.org/corporate/mne/mining.htm