As a manufacturer of electrical/electronic products which may utilize components that contain gold (Au), tin (Sn), tantalum (Ta) or tungsten (W) Digi International is aware of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act regarding Conflict Minerals (CMs) sourced from the Democratic Republic of the Congo and its adjoining countries. The CM legislation adopted late July 2010 with enabling regulations on August 22nd, 2012 requires certain companies to make an annual disclosure report to be filed with the SEC no later than June 1st, 2018.
Digi will comply with SEC regulations and OECD Guidance through Digi’s proactive and comprehensive compliance strategies. Since October of 2012 Digi’s Conflict Minerals compliance program has been proactively focusing its CM efforts on the following:
Digi is obligated to accurately report the smelters and refiners that our suppliers have identified. We are unable to simply remove certain smelters / refiners from our CMRT Template, until our suppliers have done so first. Digi International is not in direct contact, or control with smelters and we neither support, or directly source smelters located in the DRC as well as the nine adjoining countries: Angola, Burundi, Central African Republic, Congo Republic, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. We rely on our suppliers for the veracity of their smelter information.
Our CMRT Template aligns with smelters and refiners identified during the 2017 timeframe. We recognize that smelters may exist in this CMRT (Smelters List) that have been recently identified by the CFSI as no longer active, or compliant. With that said, and to the extent that the listed smelter/ refiners are implicated in failing to comply with the Conflict Minerals regulations, Digi does actively pursue the removal of smelters/refiners located in the DRC and the nine adjoining countries from our supply chain. However, if and when these smelters/refiners are removed, it is likely that their absence from our supply chain may not be reflected in our current CMRT until the end of the current year.
Digi International Action Plan:
- Maintain communication with relevant Supply Chain to notify Digi International expectations.
- Request to remove non-compliant smelters.
- Encourage suppliers to source from Conflict free Smelters.
Group components and materials into categories based on whether they contain Gold, Tin, Tantalum or Tungsten. Query our supply chain partners annually to make a reasonable determination if raw, consumable or purchased components have conflict-metals origins. We have received statements and/or EICC-GeSI Conflict Mineral Reporting Templates from all suppliers that have been defined to use one of the listed metals along with response from more than 90% of our supply base.
Digi Contracts with Silicon Expert to provide compliance information on components as available in the market and works with outside service providers to help ensure that we follow best practices and thought leadership in relation to conflict minerals issues.
Digi Customers can download an electronic copy of Digi International’s EICC Conflict Minerals template from the web site: EICC-GeSI Conflict Minerals Reporting Template Rev 5.10 ("Template"). The template will be done once per year. We will use the most current CMRT revision available from EICC/GeSi Conflict Minerals. This template applies to the Digi International product portfolio. We cannot provide a separate CMRT report for any one specific skew.
As always, Digi wishes to assure its customers and distribution partners of its continuing progress and diligence regarding Conflict Minerals. Should you have any further questions please contact by email email@example.com at your convenience.
The information in our response is based on information provided to us by our suppliers, other third parties, and information in our existing records. We are not able to verify the accuracy or completeness of information provided to us by third parties. Our responses are as of the date hereof and we undertake no obligation to update or modify the information.