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Conflict raw materials - US Conflict Minerals Policy

The United States Congress sees a direct link between the mining and trade in tin, tungsten, tantalum and gold ("conflict minerals") and human rights violations in the Democratic Republic of Congo and its neighbouring regions (hereinafter summarized under "DRC").

AIGO-TEC GmbH undertakes to act responsibly in the procurement of conflict minerals for the production of its products. AIGO-TEC GmbH will therefore refrain from knowingly supporting, favouring or otherwise promoting armed conflicts in the DRC by trading conflict minerals. Non-governmental armed groups or militias that illegally collect or control taxes on mines, transport routes, trading points or actors in the upstream supply chain will not be knowingly supported by AIGO-TEC GmbH - neither directly nor indirectly. AIGO-TEC GmbH has also developed comprehensive guidelines that strictly prohibit the participation of their employees in all forms of corruption and bribery. We expect all suppliers in our supply chain to follow these principles as well.

AIGO-TEC GmbH applies due diligence procedures with regard to conflict minerals in accordance with nationally and internationally recognized framework guidelines, some of which also include the OECD guidelines of the "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas".

AIGO-TEC GmbH also supports industry initiatives such as the Conflict Free Smelter Program (CFS) to ensure that the conflict minerals used to produce our products originate from conflict-free sources and do not help to promote armed conflicts in the DRC. Suppliers are encouraged to source raw materials from conflict-free sources and, as far as possible, from certified melts.

 Requierements for suppliers

Wherever possible, AIGO-TEC GmbH incorporates their principles for the responsible procurement of conflict minerals into the contractual conditions with suppliers and strives to raise awareness of this problem within their supplier base. We present our position paper to our suppliers and expect them to draw up similar guidelines with regard to their own supply chains.

AIGO-TEC GmbH encourages suppliers of components, parts or products containing conflict minerals to obtain them from conflict-free sources. We expect our suppliers to draw up their own guidelines for the procurement of conflict minerals, implement them and, in turn, communicate them to their own suppliers. Whenever possible, they should also oblige their own suppliers to draw up and implement similar guidelines. AIGO-TEC GmbH expects their suppliers - in cooperation with their own suppliers - to trace the origin of conflict minerals back to at least the point of melting and to encourage them to apply a standard reporting process. AIGO-TEC GmbH reserves the right to request further evidence from their suppliers about the origin and supply chain of conflict minerals, if necessary up to the mine in which they were mined. We expect suppliers to keep traceability documents of this type for five years and to present them to AIGO-TEC GmbH when requested to do so..

Suppliers are encouraged to support industry initiatives in a bid to improve the traceability of conflict minerals and responsible practices in their global supply chain.

AIGO-TEC GmbH aims to maintain long-term relationships with their suppliers, relies on sustainable solutions whenever possible and works together with their suppliers to drive improvements. Suppliers who violate the guidelines of AIGO-TEC GmbH set out here must commit to a corrective action plan and implement it within a reasonable time. AIGO-TEC GmbH reserves the right to demand evidence from their suppliers about the effectiveness of the corrective measures initiated and to carry out an assessment of the supply chain. If a supplier permanently violates the guidelines and does not implement corrective measures, this may lead to further measures, including termination of the business relationship.