Conflict Mineral Policy
INTRODUCTION
Proceeds from the mining of certain
minerals in the Democratic Republic of Congo (the “DRC”) and countries
adjoining it have been linked to violations of human rights through the
funding of illegal armed groups. In accordance with the Dodd-Frank Wall
Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), the
United States Securities and Exchange Commission (the “SEC”) has adopted
a rule to bring greater supply chain transparency to the use of conflict
minerals. Timex Group (“Timex”) has proactively taken
measures on the sources and origins of Conflict Minerals to ensure a
conflict-free supply chain. DEFINITIONS
Conflict Minerals: Refers to
columbite-tantalite (coltan), cassiterite, gold, wolframite, or their
derivatives: tantalum, tin and tungsten; or any other mineral or its
derivatives determined by the Secretary of State to be financing
conflict in the Democratic Republic of the Congo or an adjoining
country. DRC Adjoining Countries: Are
countries that share an internationally recognized border with the
Democratic Republic of the Congo. The following countries are currently
recognized as “adjoining countries”: Angola, Burundi, Central African
Republic, Congo Republic (a different nation than DRC), Rwanda, South
Sudan, Uganda and Zambia.
DRC Conflict Free: As defined in
Section 1502 of the Dodd-Frank Act, “a product may be labelled as ‘DRC
conflict free’ if the product does not contain conflict minerals that
directly or indirectly finance or benefit armed groups in the Democratic
Republic of Congo or an adjoining country.” Conflict minerals obtained from recycled
or scrap sources: Conflict minerals obtained from recycled metals
are reclaimed end-user or post-consumer products or scrap processed
metals created during product manufacturing. Recycled metals include
excess, obsolete, defective and scrap metal materials containing refined
or processed metals that are appropriate to recycle in the production of
tin, tungsten, tantalum or gold. Minerals partially processed,
unprocessed or a bi-product from another ore are not included in this
definition. POLICY
Timex is committed to conducting its
worldwide business operations in a manner that complies with applicable
laws and regulations regarding conflict minerals. To comply with these
requirements, Timex is committed to:
·
Inform direct suppliers about this
Conflict Minerals Policy and its relationship to the company’s Supplier
Code of Conduct.
·
Work with its direct suppliers and
sub-suppliers to understand the chain of custody for conflict minerals
at least to the smelter or refiner level.
·
Take measures to source parts and
components from its direct suppliers and sub-suppliers that are DRC
conflict-free. These measures may include adopting, disseminating and
incorporating this policy in related purchase orders, contracts and
other appropriate agreements with suppliers.
·
Encourage direct suppliers to track and
improve their performance in sourcing minerals from their suppliers and
sub-suppliers that are validated as being DRC conflict-free in
accordance with a national or internationally recognized due diligence
framework. Timex encourages its suppliers to:
·
Assist Timex in complying with the
regulations and any other applicable regulations related to conflict
minerals and provide all necessary declarations.
·
Undertake reasonable due diligence within
their supply chain to determine the chain of custody and origin of the
conflict minerals. Due diligence includes developing policies and
management systems to use DRC conflict free minerals, including making
these requirements apply to their direct suppliers and sub-tier
suppliers and requiring them to do the same with lower tiers of
suppliers.
·
Take measures to purchase parts,
components or materials from their direct suppliers and sub-tier
suppliers who source minerals for their products from smelters or
refiners validated as being DRC conflict free in accordance with a
nationally or internationally recognized due diligence framework. COMPLIANCE
This policy applies to Timex’s global
business operations. Employees whose responsibilities relate to the
supply or sourcing of parts, components and materials should be informed
and are expected to comply with these requirements and associated
legislation or regulation. NON-COMPLIANCE
Timex will work with its suppliers to seek
remedies for non-compliance with this policy. These remedies may include
suspension or discontinuing engagement with the supplier. REPORTING VIOLATIONS Violations or potential violations of this
policy should be reported by employees to your manager or to the Legal
Department. ADDITIONAL INFORMATION / CONTACTS
Contact the Legal Department for questions or
concerns regarding compliance with this policy. |