Conflict Minerals Policy (v.05.26.20)
Environmental After Link
In 2010, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) Section 1502 (“§ 1502”) requiring the Securities and Exchange Commission (“SEC”) to issue rules specifically relating to the use of “Conflict Minerals” within manufactured products. Conflict Minerals are defined by the US Law as tin, tantalum, tungsten and gold (also known as the “3TGs”) and related derivatives originating from the Democratic Republic of the Congo (“DRC”) and adjoining countries (collectively, “DRC Region”). The SEC rules require any SEC registrant whose commercial products contain any 3TGs to determine whether the minerals originated from the DRC Region, and, if so, whether they are conflict free. By enacting this provision, Congress intends to further the humanitarian goal of ending the extremely violent conflict in the DRC Region, which has been partially financed by the exploitation and trade of Conflict Minerals originating in the DRC Region.
Cognex Corporation (“Cognex”) is committed to complying with the § 1502 requirements by working with our supply chain partners and taking reasonable steps to ensure 3TGs are not sourced by Cognex or our supply chain partners in a way that would directly or indirectly benefit armed groups responsible for serious human rights abuses in the DRC Region.
It is the desire of Cognex to make responsible sourcing decisions for all of our 3TG products, including materials and components contained therein (collectively, “3TG Product”); however, due to the complexity of our supply chain and the number of suppliers involved, this is a process that will evolve over time. In the meantime, Cognex will take reasonable steps to map our 3TG Product, back to the smelter.
Expectations of Suppliers
Cognex expects our suppliers to partner with us and also make responsible sourcing decisions. We expect our suppliers, at a minimum, to comply with our requests to provide statements and perform due diligence about the source of any conflict minerals in their products which are provided to us. Cognex’s direct suppliers may have to require successive upstream suppliers to complete a Conflict Minerals survey, such as the Electronic Industry Citizenship Coalition-Global e-Sustainability Initiative (“EICC-GeSI) Conflict Minerals Reporting Template or similar, until the smelter is identified. Cognex is committed to take reasonable action for suppliers who are not conflict free and/or do not comply with our disclosure requests as outlined in this policy.