Conflict Minerals Report for the Calendar Year 2016
The proServ electronic GmbH is aware of its responsibility concerning ‚conflict minerals‘ and we take special efforts neither to support nor to promote the violence and abuse of human rights in Central Africa in connection with mining of the minerals gold, tantalum, tin and tungsten.
Due to this reason meeting the obligations concerning transparency and consumer consciousness (mentioned in the Dodd-Franck Act of the United States of America) is very important to us.
In order to be in the position to indicate the usage of conflict minerals in our products we are depending on the information given by our suppliers. They are the only reliable source of information concerning the materials used during the process of production of our products.
Because of this we annually prepare studies. We’ve been doing this for various years now. In these studies we ask our suppliers to indicate their refineries. We are aware that this can cause a long retracing process within the supply chain and therefore it can be a very time-consuming process.
To simplify the retracing process we’ve decided to cooperate with the company iPoint Conflict Minerals Platform (‚iPCMP‘). iPoint is world-leading in conflict minerals compliance. Their web-based software solution collects and processes data about conflict minerals via the complete supply chain very efficiently.
For the calendar year 2016 proServ electronic GmbH has sent communication letters to more than 150 suppliers, notifying them of our expectations concerning Due Diligence Measures and instructions to complete the Template.
The analysis of the data showed that – compared to the past years – our suppliers indicated a much higher attendance and also a considerably higher sense of responsibility concerning the violation of human rights in Central Africa in connection to mining of gold, tantalum, tin and tungsten. This development can be seen very positive.
Of the suppliers surveyed, 28,6 % (18,5% in 2015) of the suppliers of tin, 31,5% (19,5% in 2015) of the suppliers of gold, 13,4% (11,4% in 2015) of the suppliers of tantalum and 9,1% (1,1% in 2015) of the suppliers of tungsten advised that the Covered Countries were not the origin of the Conflict Minerals supplied to proServ electronic GmbH.
For the remaining responses, we were not able to determine with any specifity if the Conflict Minerals originated in the Covered Countries due to insufficient information. proServ electronic GmbH is currently following its Due Diligence Procedures to obtain additional information from our suppliers in order to make such determination. In the event one of our suppliers indicates in its Template response that it might be sourcing Conflict Minerals from the Covered Countries, our approach is to follow-up and collect more detailed information from this supplier. These efforts include inquiring of such suppliers whether they performed Due Diligence Procedures for non-certified smelters and whether they were able to determine if the Conflict Minerals financed or benefited armed groups in the Covered Countries.
Going forward, proServ electronic GmbH will continue its efforts for the suppliers and will also focus on continuous improvement efforts to improve the return rate of our future survey efforts as well as the completeness of our suppliers‘ responses to our inquiries.
Risk Mitigation Measures
In addition to current processes and procedures, in order to mitigate the risk that Conflict Minerals in the supply chain benefited armed groups in the Covered Countries and to identify the origin of those minerals, proServ electronic GmbH will continue to perform the necessary follow-up procedures with the suppliers for which no response was received or suppliers which provided inconclusive responses to the survey. Furthermore proServ electronic GmbH will enhance its Due Diligence measures for existing and new suppliers identified as part of the procedures in the respective year.
At this time, proServ electronic GmbH is not able to determine whether the products produced by or for us in 2016 are completely free of Conflict Minerals.