2020 Conflict Minerals Policy

Bullitt Group, making innovative products and services that bring together global brands and connected device technologies, is committed to make informed decisions about sourcing minerals in its supply chain.

The company adheres to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, and it requires the continuous maintenance of the same compliance level from its manufacturing suppliers.

 

The company is committed to that the tantalum, tin, tungsten and gold (together 3TG or “Conflict Minerals”) in its products does not directly or indirectly finance or benefit armed groups that are serious offenders of human rights in the Democratic Republic of the Congo or an adjoining country.

 

In order to improve the transparency of the sources of conflict minerals used for the production or left in its products, the company requests its manufacturing providers to fill in per product the Conflict Minerals Reporting Template (CMRT) published by the Responsible Minerals Initiative.

 

In the event of incomplete or no responses to the CMRT data request after several attempts the company reviews its relevant risk analysis which, if practicable and reasonable, may result in initiating a disengagement process with such non-cooperative suppliers.

 

The company encourages its staff, suppliers and customers to report any Conflict Mineral issues or potential issues and welcomes innovative ideas and procedures that promote the collection and reuse of Conflict Minerals.

 

The company distributes this policy to all of its product manufacturing partners with the intent of applying the necessary provisions in future contractual supply agreements.

 

The CPO is responsible for the adequacy and efficiency of this policy within the company.

Reviews and updates of this policy shall take place annually to reflect changes to legislation, and emerging good practices or business needs.

Copies of the company’s Conflict Minerals Policy shall be made available to its customers, suppliers and other organisations with a direct interest.