Design of Due Diligence
With the objective of determining whether the Conflict Minerals used in EXFO's products originated in a Covered Country and financed or benefitted an armed group in the Covered Country, the due diligence completed by EXFO conforms to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Second Edition).
Product Description
EXFO is a leading provider of next-generation test, service assurance and end-to-end quality of experience solutions for mobile and fixed network operators and equipment manufacturers in the global telecommunications industry. EXFO’s products consist of many components and parts, supplied by numerous suppliers. EXFO believes 3TG are found within the electronic components of EXFO products, supplied by its electronics-related suppliers. These components consist of chip sets, semi-conductors, active and passive components, connectors and batteries. Other related electronics suppliers provide EXFO with computers and printed circuit boards, which EXFO also believes contains 3TG. The other components of EXFO's products from other suppliers consist of plastic injection components, sheet metal, machined aluminum and steel components. EXFO believes that these components do not contain 3TG.
Due Diligence Measures Performed
Due to the size of EXFO, the complexity of its products, and the ever evolving supply chain, the evaluation and due diligence measures performed were carefully constructed in phases in order to thoroughly determine the source and chain of custody of the Conflict Minerals used. EXFO established an inventory of the Conflict Minerals it uses, the source of those Conflict Minerals, and in which products the Conflict Minerals are considered necessary to the functionality of its products. In order to identify and assess the risk in its supply chain, EXFO prioritized its due diligence on those electronics-related suppliers whom it believes to be providing components that contain 3TG. In addition, in order to conduct its due diligence process as accurately as possible, EXFO also evaluated all other suppliers, including mechanical and packaging. While prioritizing those electronics-related suppliers, EXFO also reviewed all existing agreements with all suppliers. In addition, EXFO surveyed all suppliers (the “Survey”) to determine the RCOI of Conflict Minerals, using the Electronics Industry Citizenship Coalition (“EICC”) Standard Conflict Minerals reporting format, and the Conflict-free Sourcing Initiative (“CFSI”). The Survey was developed to facilitate the disclosure by suppliers of the source of its Conflict Minerals to EXFO. As part of the review of the Surveys, EXFO cross-checked named smelters against the list of known smelters using the Conflict-Free Smelter list launched by the EICC (www.conflictfreesmleter.org). A conflict-free designation by a recognized industry group, although not required to be provided by each supplier, is encouraged and welcomed by EXFO. In addition, all suppliers are also required to submit a declaration stating they have provided true and complete information and any changes to such information will be brought to the immediate attention of EXFO.
In addition to the information gathered from each supplier from the Survey required by EXFO, public information by each supplier in EXFO’s supply chain was searched and documented. Such information includes Conflict Mineral policies, Covered Countries conflict-free designations from recognized industry groups, and other certifications and statements made by the supplier in reference to Conflict Minerals.
|