Conflict Minerals Policy

CONFLICT MINERALS POLICY STATMENT

Arvato is committed to sourcing components and materials from suppliers that share our respect for human rights, ethics and the protection of the environment. On August 22, 2012, the U.S. Securities and Exchange Commission (“SEC”) issued the final rules on “conflict minerals” under Section 1502 the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). The Dodd-Frank Act requires publicly-traded companies to disclose any minerals used to fund extreme violence in the Democratic Republic of Congo (“DRC”) and adjoining regions – including tantalum, tin, gold or tungsten – that are necessary to the functionality or production of products they manufacture (or contract to manufacture).

 

As a privately-held company, Arvato is not subject to the SEC disclosure requirement of the Dodd-Frank Act. However, as a supply-chain solutions provider, Arvato is committed to maintaining human rights, and further committed to ensuring that any products we source do not contain conflict minerals or contribute to the conflict in the DRC. Accordingly, as part of our conflict minerals policy, Arvato requires all of our suppliers to provide us with completed declarations on the use of tantalum, tin, gold or tungsten in the products supplied to Arvato – and, if such minerals are used, to perform due diligence and audits in evaluating their supply chain to confirm that such minerals do not have origins in the DRC or adjoining regions.

 

We expect our suppliers of components containing the above minerals to source them only from non-conflict sources (and to take similar measures with their suppliers to ensure alignment throughout the supply chain).