UCT, Inc. Conflict Minerals Policy
There has been increased awareness regarding the human rights violations in the mining of certain
minerals from an area known as the "Conflict Region"; the Democratic Republic of the Congo (DRC) and
surrounding countries. Through the Dodd-Frank Wall Street Reform and Consumer Protection Act of
2010, publically traded companies have been chartered to practice reasonable due diligence with their
supply chain to determine if "conflict minerals" used in their products are being sourced from mines
controlled by non-government or unlawful military groups within the Conflict Region. The definition of
"Conflict Minerals" refers to tin, tantalum, tungsten and gold (3TG).
Tracing materials back to their mine of origin is a complex endeavor but an important aspect of
responsible sourcing. UCT has followed industry guidelines, such as the joint Electronic Industry Citizen
Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) which are taking action to address
responsible sourcing through the development of the Conflict-Free Smelter (CFS) program aiming to
enable companies to source conflict-free minerals.
As such, UCT, as good corporate citizens, understands that it is our responsibility to implement
strategies that support the objectives of the U.S. regulations on the supply of "Conflict Minerals".
Therefore, we are committed to:
Continuous development of strategies and processes aimed at preventing the use of conflict
minerals or derivative metals necessary to the functionality or production of our product(s) that
finance or benefit armed groups in the Conflict Region.
Not knowingly procure specified minerals that originate from facilities in the "Conflict Region"
that are not certified as conflict free.
Expecting suppliers whose products contain conflict minerals to establish policies, due diligence
frameworks, and management systems consistent with the Organization for Economic Cooperation
and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict-Affected and High Risk-Areas that are designed to accomplish this goal,
and requiring their suppliers to do the same.
UCT believes in establishing and maintaining long-term relationships with suppliers whenever possible.
However, if we determine that any supplier is, or a reasonable risk exists that it may be, violating this
policy, then we will require the supplier to commit to devise and undertake suitable corrective action to
move to a conflict free source. If suitable action is not taken, we will look to alternative sources for the
product. If we determine that any of the components of our products contain minerals from a mine or
facility that is "non-conflict free", we will work towards transitioning to products that are "conflict free".
Last Updated: November 20, 2015
UCT Anti-Slavery and Human Trafficking Policy Statement
UCT is dedicated to conducting business in an ethical and responsible manner and committed to full
compliance with applicable laws and regulations, including the prevention of slavery and human
trafficking, in its business operations. These values are reflected in our Code of Business Conduct and
In addition, UCT contractually requires strategic product suppliers to conduct their operations in a
manner that complies with all applicable laws and regulations.
To verify compliance with its global supply chain standards, UCT:
Verifies compliance with prospective direct product suppliers during the supplier evaluation
Conducts annual audits with strategic and key direct product supplier operations
Requests written certification from strategic direct product suppliers that the materials
incorporated into its products comply with applicable laws and regulations, including laws
regarding slavery and human trafficking of the country or countries in which they are doing
The verification and audit are conducted by UCT employees, and the audit may be announced or
UCT direct product suppliers, employees and contractors who fail to comply with UCT’s expectations are
subject to corrective action up to and including termination.