Saelig Conflict Minerals Statement

 

Saelig Company, Inc. is a privately-held small business.  Although we do not manufacture or contract to manufacture any product, we share the worldwide concern that gold, tantalum, tungsten or tin (Conflict Minerals) mined in the Democratic Republic of the Congo (DRC) or adjoining countries may be making their way into the electronics supply chain.

 

The US Securities and Exchange Commission (SEC) issued final rules in August, 2012, relating to Section 1502(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  These final rules require all public companies to disclose and report annually to the Securities and Exchange Commission (SEC) if the gold, tantalum, tungsten or tin they use in their products originated from the DRC or adjoining countries.  Saelig is not a public company.  Saelig is a reseller which does not manufacture or contract to manufacture any of the products it sells.  Resellers are not required to report on products they simply buy and resell.  Regardless, we would like to observe the spirit of those rules in support of our customers who are manufacturers and public companies.

 

To that end, Saelig has polled our suppliers regarding their Conflict Minerals policies.  The results of that polling are not complete, but they offer a preliminary indication that our supply chain does not knowingly contribute to human rights violations in the DRC.  The suppliers who have responded have said that to the best of their knowledge, the gold, tantalum, tungsten, or tin which may be in some of the electronics they produce is not derived from mines in or around the conflict areas of the DRC.  So far as we know, none of our suppliers source metals directly from smelters.  

 

The production of any single electronics instrument may involve hundreds or even thousands of suppliers spread all over the world.  Most of these overseas suppliers have little or no awareness of events in the DRC and little or no knowledge of US Congressional legislation or SEC rules.  Saelig represents thousands of electronic products, most of which are manufactured overseas.  Those thousands of products involve many thousands of suppliers, sub-contractors and the suppliers of those sub-contractors.  As a practical matter, Saelig Company does not have the resources to educate and query this huge and complex world-wide supply network.  Like Saelig, many of our suppliers are smaller, privately held companies which do not have the resources or the influence to mandate a verifiable response from their suppliers.

 

Regardless of these obstacles, Saelig will continue to ask our suppliers to verify in writing the procedures they have in place to insure that the products they procure are sourced in accordance with this policy.