Telecore Policy on Conflict Metals

It has been determined that mining operations, specifically in the eastern region of the Democratic Republic of the Congo (and adjoining countries), fund “armed militias” that are directly responsible for widespread human rights violations. As a result, in July 2010 new legislation was passed requiring companies listed on the U.S. stock exchange to report annually to the Securities and Exchange Commission (SEC) a list of any products that were produced with “conflict minerals” (tin, tantalum, tungsten and gold – often referred to as “3TG”) sourced from this area of concern, as well as disclose any measures taken to eliminate the conflict minerals from their supply chains. 

This legislation is also known as the Dodd-Frank Wall Street Reform and Consumer Protection Act. Although Telecore is not listed on any U.S. stock exchange, we are a supplier to customers subject to the rule, and as such are required to flow these requirements to our supply chain in order for our customers to complete their SEC conflict minerals reporting obligations.

Telecore takes very seriously its responsibility to ensure that metals mined in the Democratic Republic of the Congo do not find their way into our supply chain. To this end, Telecore has taken several steps to facilitate and support this legislation: 

  1. Telecore has added verbiage and requirements to our distributor/vendor/supplier Purchase Orders (PO) that requires our supply chain to comply to the  Dodd-Frank Wall Street Reform and Consumer Protection Act.  Additionally, Telecore requires that our supply chain flows these requirements to any of their sub-tier suppliers. 

  2. As part Telecore’s vendor selection/approval process, Telecore has added language to our Vendor Survey that provides notice to each Telecore supplier of our company's expectations regarding our collective social responsibility in this matter. Telecore has also implemented a Conflict Minerals questionnaire in our Vendor Survey to determine the level of compliance of our supply chain.

Telecore has taken this action because we feel it is incumbent upon our supply chain to promote and maintain the high level of supply chain integrity that our customers demand by ensuring ongoing compliance with the policy requirements stated within the relative legislation.

As such, it is expected of all Telecore distributors/vendors/suppliers who incorporate metals in products supplied to our customers to trace and map their own supply chain to their smelters, seeking only to source materials from non-conflict regions. Although the complexity of the metals supply chain makes verification of the origin for conflict metals difficult, Telecore strives to assure that its suppliers are in compliance with this directive.

To support of the various global conflict metals initiatives while continuing to provide the highest quality products at competitive prices, it’s Telecore’s policy to:

  • Support the improvement of human rights in the Democratic Republic of the Congo and surrounding areas
  • Facilitate compliance with the Dodd-Frank Wall Street Reform and Consumer Protection Act
  • Direct our discretionary business, as much as practical, to vendors who have traceable supply chains, freely share their data with us, and source responsibly
  • Support our customers’ enquiries about the source of conflict metals that we use in our manufacturing