Due to violence and human rights violations in the mining of certain minerals in conflict countries around the world, the U.S. Securities and Exchange Commission has implemented reporting and disclosure requirements for Conflict Minerals (i.e. 3TG), as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Starfire Industries LLC is a privately-held small business and, as such, is not directly subject to the Conflict Minerals traceability reporting requirements of Section 1502 of the Dodd-Frank Act; however, we are sympathetic to the aims and objectives of the US legislation. Starfire Industries LLC is committed to working with its customers to supply products that meet the customer’s specifications and to promote the traceability of these minerals and the transparency of the supply chain. As a result, Starfire has adopted an internal policy on Conflict Minerals. These efforts also assist with satisfying directives of the European Union Parliament under EU Conflict Materials Regulation 2017/821 for certain Conflict-Affected and High-Risk Areas to disclose their use of conflict minerals if those minerals are “necessary to the functionality or production of a product”.
Our products, like those from many companies that manufacture and use electronics, contain chip scale and commercial off-the-shelf (COTS) material components purchased from third-party vendors which originate from countries worldwide. As a small business, Starfire Industries is unable to certify the country of origin of minerals contained in every product manufactured by our suppliers. To promote both the traceability of these minerals and the transparency of the supply chain, we endeavor to undertake the following actions:
In cases of Starfire manufactured products where we explicitly specify the use of Tantalum, Tungsten, Tin, and/or Gold, Starfire Industries sources from suppliers with a stated conflict materials policy, or suppliers provide reasonable guidance that these materials are conflict free, or an EICC-compliant material report.
In cases of Starfire manufactured products where we utilize chip scale and COTS material components potentially containing 3TG materials, we have established reasonable thresholds above which we verify the chip scale and COTS material components suppliers to have conflict mineral policies in place or can provide reasonable documentation on 3TG traceability or an EICC-compliance report.
Upon request, Starfire Industries will work with our customers to provide suitable documentation or an EICC material report for the products that we manufacture.