Conflict Minerals Policy
AML supports ending the violence and human rights violations reportedly supported by profits from the sale of certain metals mined in the Democratic Republic of Congo (DRC) or adjoining countries. Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act promotes transparency and consumer awareness of the use by U.S. publicly traded companies of “conflict minerals” (tin, tantalum, tungsten and gold, or “3TG”) thatdirectly or indirectly benefit armed groups in that region. In response to Dodd-Frank, the U.S. Securities and Exchange Commission has imposed disclosure requirements on publicly traded companies (together with the Dodd-Frank Act, the “Rule”) concerning the use of 3TG in their products, the origin of the metals used if they are not “conflict free”, and the due diligence efforts employed to determine the country of origin and chain of custody of the metals. Under the Rule ”conflict free” means the product does not contain 3TG that directly or indirectly finances or benefits armed groups in the DRC or an adjoining country.
While we use 3TG in our products, we do not purchase the metals directly from smelters or mines, so we must rely on the source information provided by our suppliers. We are engaged with our direct suppliers to trace minerals back to their origin and ensure responsible sourcing throughout the supply chain. AML is using a process based on the standardized EICC/GeSI Conflict Minerals Reporting Template to accomplish our country of origin inquiry and the preparation of the required disclosures. Should AML become aware of a supplier whose supply chain includes metals from a non-conflict free source, we will take the appropriate actions to remedy the situation as contemplated by the Rule. Our expectation is that our suppliers will do the same so that we maintain alignment with the requirements of the Rule throughout the entire supply chain.
Should you have questions about our process or this Policy, please contact firstname.lastname@example.org.