Delaware | 001-34376 | 13-3458955 |
(State or other jurisdiction of | (Commission File Number) | (I.R.S. Employer Identification No.) |
incorporation or organization) |
IEC Electronics Corp. | ||
(Registrant) | ||
May 27, 2016 | By: | /s/ Jens Hauvn |
Jens Hauvn | ||
Senior Vice President of Operations |
Team Members: | Director of Supply Chain |
Director - Financial Accounting & External Reporting | |
Supplier Quality Manager | |
Corporate Director of Environmental, Health and Safety | |
Executive Sponsors: | Senior Vice President of Operations |
Chief Financial Officer |
• | Develop a list of components, products and suppliers with the assistance of supply chain personnel at each location. |
• | Evaluate the components, products and suppliers to identify whether each contain Conflict Minerals, with the understanding that there is no minimum amount for exclusion from the requirement, using a multi-layered approach. |
◦ | IEC develops a master bill of materials (BOM) for all part numbers for all IEC locations using purchase order or receiving history reports. The master BOM is updated annually to keep information current. Any modifications due to Engineering Change Orders (ECO), new components, assemblies, suppliers or customers will be captured in the updated master BOM and due diligence procedures performed. |
◦ | We identify and assess risks in the supply chain. For the majority of our parts, tin is necessary to the functionality or production of a product manufactured. To a lesser extent tantalum, tungsten and gold are also necessary for some parts. |
◦ | Data collection and evaluation through a third party BOM manager tool identifies by component and supplier if any Conflict Minerals are present, declaration status and other sourcing data via the conflict minerals reporting template developed by the Conflict-Free Sourcing Initiative. We expect that some of IEC’s suppliers’ data will not be available through the BOM manager tool. |
◦ | Data is also collected directly from suppliers using the conflict minerals reporting template developed by the Conflict-Free Sourcing Initiative. |
◦ | Electronic Industry Citizenship Coalition (EICC) templates or other forms of supplier declarations are collected using survey software or gathered from suppliers' websites or other publicly available means. |
◦ | Supplier declarations are evaluated to determine if supplies, products or components containing Conflict Minerals purchased by IEC are derived from the Covered Countries. |
◦ | We respond to identified risks and red flags including but not limited to: Conflict Minerals sources not on EICC-Global eSustainability Initiative Conflict-Free Smelter (CFS); Conflict Minerals from areas with limited known reserves; Conflict Minerals that originate from or have been transported via a conflict-affected or high-risk area but reported as Conflict Free; and supply chains known to have sourced minerals from red flag locations. We then determine if other diligence is necessary such as further follow up direct with the supplier or members of their supply chain, audits, or review of third party due diligence audits already performed. |
◦ | MRPro is used to assess the status of supplier responses and facilitate responses to customer inquiries. |
◦ | Responses are then summarized in a master Excel file. |
◦ | Non-responses are followed up with additional survey requests and/or direct contact (e-mail, phone or in person) depending on risk. |
• | Based upon the results of the evaluation, we determine whether IEC can be identified as DRC Conflict Free, DRC Not Conflict Free or DRC Conflict Undeterminable. |
• | Audit Requirement: A certified independent private sector audit is required to express an opinion or conclusion on whether the design of the issuer’s due diligence measures are in conformity with the criteria set forth in a nationally or internationally recognized due diligence framework and whether the issuer’s description of the due diligence measures it performed as set forth in the Conflict Minerals Report is consistent with the due diligence that the issuer undertook. Currently, the only known such framework is the OECD’s “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”. A DRC Conflict Undeterminable status does not require an audit. |
• | Reporting to the customer: |
◦ | IEC issues a standard response using the EICC template unless a customer requests another format, in which case we may customize. If vendors are not found to be DRC Conflict Free, we will communicate this to our customers. |
◦ | IEC’s corporate policy regarding Conflict Minerals and disclosure regarding whether any Conflict Minerals necessary to the functionality or production of a product originated in Covered Countries will be made publicly available on our website in accordance with the Securities Exchange Act Section 13(p)(1)(E). |
• | Require new vendors to complete an EICC template prior to them being established as a vendor. |
• | Working with our customers when it is discovered that a component we source to support their product may benefit armed groups in the Covered Countries and, should the customer so determine, cooperate with the customer to change the supplier. |
Australia | Peru |
Austria | Philippines |
Belgium | Poland |
Bolivia | PT Koba Tin |
Brazil | PT Sumber Jaya Indah |
Canada | Russian Federation |
China | Saudi Arabia |
Estonia | Singapore |
Germany | South Africa |
Hong Kong | Spain |
India | Sweden |
Indonesia | Switzerland |
Italy | Taiwan |
Japan | Thailand |
Kazakhstan | Turkey |
Korea, Republic Of | United Arab Emirates |
Kyrgyzstan | United States |
Malaysia | Uzbekistan |
Mexico | Vietnam |
Netherlands | Zimbabwe |
New Zealand |