Conflict Minerals Policy
This document sets forth the policy of HSP Online GmbH regarding Conflict Minerals.
On July 21, 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into law. The Dodd-Frank Act and related 2012 U.S. Securities and Exchange Commission rules require certain companies to disclose whether the products they manufacture or contract to manufacture contain Conflict Minerals necessary for the production or the functionality of the products that are sourced from mines in the Democratic Republic of the Congo or adjoining countries. Conflict Minerals are tantalum, tin, tungsten and gold.
As a responsible company, HSP Online GmbH supports the goal of the Dodd-Frank Act of preventing armed groups in the Democratic Republic of the Congo and adjoining countries from benefitting from the sourcing of Conflict Minerals from that region.
As a distributor of products manufactured by other companies, HSP Online GmbH does not directly purchase any raw Conflict Minerals from any source and is many levels removed from the mines, smelters, and refiners that produce the metals used in the products manufactured by our suppliers.
We are requiring the following from our suppliers:
Suppliers should not include in any products sold to HSP Online GmbH any Conflict Minerals that are not DRC Conflict Free;
Suppliers should develop Conflict Minerals policies, due diligence frameworks, and management systems that are designed to prevent Conflict Minerals that are not DRC Conflict Free from being included in the products sold to HSP Online GmbH ;
HSP Online GmbH suppliers are expected to source Conflict Minerals only from sources that are DRC Conflict Free.
HSP Online GmbH reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy.
HSP Online GmbH reserves the right to request additional documentation from its suppliers regarding the origin of any Conflict Minerals included in any of their products.
Suppliers who do not reasonably comply with this Policy shall be reviewed for future business.
In the event HSP Online GmbH determines that a supplier’s efforts to comply with this Policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, HSP Online GmbH reserves the right to take appropriate actions up to and including discontinuing cooperation with the supplier.