Kimball Electronics, Inc. Conflict Minerals Policy Statement

 
Minerals mined in the Democratic Republic of Congo (DRC) and adjoining countries may be making their way into the electronics industry supply chain.   Some mining operations in the DRC have been linked to poor labor and environmental practices, and there is evidence that some mining and transportation of minerals in the Eastern provinces of the Democratic Republic of Congo (DRC) are funding conflict in the country by funding illegal armed groups.  As part of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the United States Securities and Exchange Commission (SEC) passed legislation which requires U.S. companies to report on the origin of these conflict minerals including tin, tantalum, tungsten and gold, often referred to as 3TGs.         

Kimball Electronics, Inc. is committed to ethical practices and compliance with all applicable laws and regulations.  While we do not source these metals directly, they may exist in the materials and components we source.  We are therefore committed to working with our customers and suppliers to responsibly source the materials and components we use in manufacturing our customers’ products which may contain these minerals.   To comply with the SEC reporting regulations relating to conflict minerals, Kimball requires chain of custody declarations from our suppliers to verify the origin of the conflict minerals contained in their products.    

In addition, we require the following from our suppliers:

• to source materials from socially responsible sub-tier suppliers and manufacturers 
• to assist us to comply with the SEC regulations related to conflict minerals and to provide all necessary declarations 
• to  source 3TGs from smelters validated by an independent third party audit 
• to undertake reasonable due diligence within their supply chain to determine the origin of the conflict minerals, including developing policies and management systems preventing the use of conflict minerals or derivative metals sourced from mines that directly or indirectly finance armed groups through mining or mineral trading in the DRC or any adjoining country, and to pass these requirements along to their sub-tier suppliers and require them to do the same with lower tiers of suppliers. 

We require the following from our customers:

• to design in components that can be sourced from socially responsible suppliers 
• to assist us in complying with the SEC regulations related to conflict minerals and to assist in gathering declarations where the supply chain has been established by our customer 
• to support supply chain changes required to eliminate DRC conflict minerals from the products 

In addition, we will work with our suppliers and also our customers, where the supply chain has been established by our customer, to seek remedies for non-compliance.  

The process of tracing the conflict minerals through the supply chain is complicated and timeconsuming.  Therefore, we will rely on industry initiatives, such as the Conflict Free Smelter Program, for assistance in complying with the SEC reporting requirements on conflict minerals.   

KEI’s policy is to provide one finalized CMRT the first week of April each year. The rationale behind this policy/timeline includes:

• Being fully compliant with the regulations, which require that we evaluate the supply chain and report compliance status for the entire calendar year (January-December) 
• Providing you with the most complete and accurate data.  While we may survey suppliers more than once throughout the calendar year (to ensure that we are contacting all applicable suppliers), we also need time to validate and complete due diligence on the information we receive.  In previous years, we may have provided an interim CMRT, but we determined that this led to problems for both us and our customers including inaccurate and incomplete data, and misunderstandings about whether the interim CMRT was final. 
• Providing interim CMRTs significantly increased the workload of our Conflict Minerals team which was not value-added. 

You may find our Conflict Minerals Policy @ https://www.kimballelectronics.com/supply-chain/conflict-minerals-policy

Kimball Electronics is committed to working with our customers and our suppliers to ensure effective implementation of this legislation. 

Rev 10.24.2019