RELM Wireless Corporation
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(Exact name of registrant as specified in its charter)
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Nevada
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001-32644
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59-34862971
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(State or other jurisdiction of incorporation or organization)
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(Commission
File Number)
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(IRS Employer Identification No.)
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7100 Technology Drive
West Melbourne, FL
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32904
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(Address of principal executive offices)
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(Zip Code)
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William P. Kelly
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(321) 984-1414
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(Name and telephone number, including area code, of the
person to contact in connection with this report.)
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RELM Wireless Corporation
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(Registrant)
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By: /s/ William P. Kelly
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Date: June 2, 2014
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Name: William P. Kelly
Title: Executive Vice President &
Chief Financial Officer
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1.
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RELM has established a management system for conflict minerals.
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a.
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RELM has structured internal management to support supply chain due diligence.
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i.
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RELM has adopted and implemented a conflict minerals compliance policy and procedures that are consistent with that of the EICC-GeSI Guidance, for its supply chain.
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ii.
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A team has been formed to administer the conflict minerals management program. The team is comprised of Company employees, including responsible management, and reports to the Company's Executive Vice President and chief financial Officer.
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b.
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RELM conducts surveys of its direct suppliers to determine whether the products they provide to RELM contain potential conflict minerals, using the Conflict Minerals Reporting Template issued by the EICC and GeSI (the "EICC-GeSI Template").
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c.
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RELM compares the smelters and refiners identified by the suppliers in their survey responses against a list of smelter facilities that have been identified as "conflict free" by the EICC/GeSI Conflict Free Smelter (CFS) program for tantalum, tin, tungsten and gold.
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d.
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RELM requires its suppliers to support it conflict minerals compliance efforts through contractual methods. For example, RELM has incorporated terms and conditions in its procurement documents which require the supplier to certify that its product is "conflict free."
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2.
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RELM has designed and implemented a strategy to respond to identified risks. RELM's strategy includes the following:
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a.
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Findings of supply chain risk assessment are reported by the Conflict Minerals Team to the team lead (EVP & CFO) and the Company's President & CEO.
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b.
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RELM works with suppliers to identify and use alternate suppliers for any component deemed to include conflict minerals from a Covered Country.
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c.
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RELM has mechanisms in place whereby its employees can report violations of its conflict minerals policies. RELM has also provided training to relevant employees on its conflict minerals policies.
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d.
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RELM has incorporated terms and conditions in its procurement documents (e.g. purchase order contracts), which require suppliers to certify their product to be conflict free.
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3.
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RELM complies with Step 4 of the OECD Guidance through encouraging its direct suppliers to purchase from EICC's Conflict Free Smelter ("CFS") Compliant Smelters.
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4.
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RELM complies with Step 5 of the OECD Guidance through making its conflict mineral reports ("CMR") available on its website.
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1.
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Products – two-way land mobile radios, repeaters and base stations.
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2.
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RELM, as a purchaser of finished components, and its suppliers of which it is aware, are several layers removed from the mining of any potential conflict minerals that may be contained in the products. Accordingly, RELM is unable to determine the origin of these minerals with certainty.
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